At Aerapass, we have developed comprehensive AML/CTF policies and procedures to ensure compliance with regulatory requirements and to effectively mitigate the risks of money laundering and terrorist financing. Our approach includes:

1. Customer Due Diligence (CDD): We implement rigorous CDD procedures to verify the identity of our customers and understand their business activities. This includes collecting and verifying identification documents and conducting background checks.

2. Risk Assessment: We conduct regular risk assessments to identify and evaluate potential risks associated with our customers, products, services, and geographic locations. This helps us tailor our AML/CTF efforts based on the level of risk.

3. Transaction Monitoring: We use advanced monitoring systems to continuously track customer transactions. These systems are designed to detect unusual or suspicious activities, which are then flagged for further investigation.

4. Suspicious Activity Reporting: We have established clear procedures for reporting suspicious activities to the relevant authorities. Our compliance team reviews and investigates any flagged transactions and, if necessary, files Suspicious Activity Reports (SARs).

5. Employee Training: Our employees receive regular training on AML/CTF regulations and best practices. This ensures that they are well-equipped to recognize and respond to potential risks.

6. Record Keeping: We maintain detailed records of all AML/CTF-related activities, including customer identification, transaction monitoring, and suspicious activity reports. These records are securely stored and regularly reviewed to ensure compliance.

7. Independent Audits: We engage independent auditors to review our AML/CTF program periodically. Their insights help us continuously improve our policies and procedures.

Overall Comment: By implementing these measures, we aim to create a secure and compliant environment for our customers and our business operations