QADIRAH INC.

ANTI-MONEY LAUNDERING (AML) POLICY

Effective Date: 9/29/2019
Last Revised: 9/29/2024
Reviewed By: Compliance

Policy Statement

Qadirah Inc. is committed to ensuring full compliance with all applicable laws, regulations, and standards regarding Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF). This policy outlines the responsibilities and procedures designed to prevent and detect money laundering activities within our operations.

Objectives

The primary objectives of this AML policy are to:

1. Prevent Qadirah Inc. from being used, intentionally or unintentionally, for money laundering or terrorist financing activities.
2. Ensure compliance with applicable laws and regulations, including the Bank Secrecy Act (BSA) and the USA PATRIOT Act.
3. Establish a framework for identifying, assessing, and mitigating money laundering risks.
4. Provide guidelines for reporting suspicious activities to the appropriate authorities.

Scope

This policy applies to all employees, directors, and officers of Qadirah Inc., as well as third-party vendors and partners conducting business on behalf of the company. All must adhere to this policy in the course of performing their duties and responsibilities.

Definitions

• Money Laundering: The process of disguising the proceeds of illegal activities as legitimate funds.
• Terrorist Financing: The use of funds to support terrorist activities.
• Suspicious Activity: Any transaction or behavior that raises red flags regarding the legitimacy of a client or source of funds.

Roles and Responsibilities

1. Board of Directors and Senior Management:
   • Ensure that an effective AML program is implemented and maintained.
   • Allocate adequate resources to ensure compliance with AML obligations.
   • Oversee the training and education of employees regarding AML responsibilities.
2. AML Compliance Officer:
   • Appointed by senior management, the Compliance Officer is responsible for day-to-day oversight of the AML program.
   • The officer must ensure proper implementation of internal controls, ongoing training, risk assessment, and reporting of suspicious activities.
3. Employees:
   • Employees must be vigilant and report any suspicious activity to the AML Compliance Officer.
   • Complete mandatory AML training annually to remain informed of compliance responsibilities.

AML Program Components

1. Customer Due Diligence (CDD) and Know Your Customer (KYC):
   • Verify the identity of all new clients before entering into a business relationship.
   • Conduct ongoing monitoring of clients and their transactions to detect suspicious patterns.
   • Ensure that customer records are updated and that high-risk clients are identified and managed according to stricter scrutiny.
2. Risk Assessment:
   • Regularly assess the company’s exposure to money laundering risks.
   • Ensure that high-risk areas, customers, and transactions are identified and mitigated.
3. Transaction Monitoring:
   • Implement monitoring systems to detect suspicious transactions.
   • Flag and review large or unusual transactions that may indicate money laundering or terrorist financing.
4. Suspicious Activity Reporting (SAR):
   • Employees must report any suspicious transactions or behavior to the AML Compliance Officer.
   • The Compliance Officer will determine whether to file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN).
5. Record-Keeping:
   • Maintain records of all transactions, customer information, and due diligence documents for a minimum of five years.
   • Ensure that records are available for review by regulators and auditors.
6. Training and Awareness:
   • Provide regular AML training to all employees, tailored to their roles and responsibilities.
   • Ensure that new employees complete AML training within 30 days of hire.

Reporting Procedures

• Any employee who suspects money laundering or suspicious activities must report the matter to the AML Compliance Officer immediately.
• The AML Compliance Officer will review and investigate the report and decide whether it warrants a SAR filing.
• Qadirah Inc. will cooperate fully with law enforcement and regulatory agencies as required.

Review and Audit

• The AML policy and procedures will be reviewed annually or whenever there are changes in applicable laws or regulations.
• Internal audits will be conducted periodically to ensure the effectiveness of the AML program.

Penalties for Non-Compliance

Non-compliance with this policy may result in disciplinary action, including termination of employment. In cases of regulatory violations, legal action may be taken against the company and responsible individuals.

Conclusion

Qadirah Inc. is dedicated to maintaining the highest standards of integrity and transparency. This AML policy is critical in safeguarding our company from being exploited for money laundering or terrorism financing purposes.