Anti-Money Laundering and (CTF), Counter Terrorism Financing Policies
and Client Due Diligence (CDD)March 24, 2022
SCOPE OF THE POLICYThe Garage Syndicate Management LLC (hereinafter — The Garage) and its subsidiaries/affiliates are subject to various anti-money laundering (AML) laws and regulations relevant to the specific business and jurisdiction where the business operates. The Garage commits to comply with applicable regulations and ensure that appropriate measures are taken to combat money laundering, terrorism financing and financial crime.This AML/СTF/CDD Program is designed to establish and Anti-Money Laundering Program and Procedures of Customer Due Diligence for the users of our business as required by applicable law and regulations in our residence country, USA and worldwide.Our AML/СTF/CDD Program are risk-based. That means that the program’s AML policies, CDD procedures and internal controls are designed to address the risk of money laundering specific to our business. We must identify that risk by looking at the type of customers we serve, where customers are located, and the types of services we offer.We have designated a Managing Member as our AML/СTF/CDD Program Compliance Person, with full responsibility for our AML/СTF/CDD Program. He has a working knowledge of the applicable rules and its implementing regulations and is qualified by experience, knowledge and training.The duties of the Compliance Person will include monitoring our compliance with AML obligations, overseeing communication and training for employees, and filing necessary reports if applicable. The Compliance Person will also ensure that the firm keeps and maintains all of the required AML records and will ensure that necessary reports are filed with the authorized authority when appropriate. The Compliance Person is vested with full responsibility and authority to enforce our AML/СTF/CDD Program.The Garage AML/СTF/CDD Program, procedures and internal controls are designed to ensure compliance with all applicable AML/СTF/CDD regulations. The policies will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.AML COMPLIANCE COMMITTEEIt is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the applicable legislation worldwide and its implementing regulations.Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex Our AML policies, procedures and internal controls are designed to ensure compliance with all applicable regulations and rules and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business.KNOW YOUR CUSTOMER STANDARDS AND CUSTOMER DUE DILIGENCEThe Garage have established, documented and maintain Know Your Customer (KYC) and Customer Due Diligence (CDD) that are integral part of the The Garage AML/СTF/CDD Program. The Garage uses a professional KYC service: SUM AND SUBSTANCE LTD https://sumsub.com/VERIFYING INFORMATIONCustomer Identification Program and CDD Procedures We will collect the following minimum information from the users of our services:1. Fill Name2. Country of citizenship3. Residence address4. Date of birth5. Type of accredited investor6. Tax ID number7. Email8. Telephone number9. Proof of residence10. Selfie11. WatchlistsThe Garage do not open or maintain customer accounts within the meaning of applicable laws, in that we do not establish formal relationships with "customers" for the purpose of effecting transactions in cash or any other financial instruments. If in the future we elect to open customer accounts or to establish formal relationships with customers for the purpose of effecting transactions, we will first establish, document and ensure the implementation of appropriate CIP procedures.
We will document our verification, including all identifying information provided by a customer, the methods used and results of verification, and the resolution of any discrepancies identified in the verification process. We will keep records containing a description of any document that we relied on to verify a customer’s identity, noting the type of document, any identification number contained in the document, the place of issuance, and if any, the date of issuance and expiration date. With respect to non-documentary verification, we will retain documents that describe the methods and the results of any measures we took to verify the identity of a customer. We will also keep records containing a description of the resolution of each substantive discrepancy discovered when verifying the identifying information obtained. We will retain records of all KYC information, transactions and customer`s account activities for 10 (ten) years after the account has been closed or last transaction was made.
CUSTOMERS WHO REFUSE TO#NBSP;PROVIDE INFORMATIONIf a customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the designated employee shall notify their Team. The Garage Team will decline the application and notify the AML Compliance Officer.
GENERAL CUSTOMER DUE DILIGENCE AND RISK BASED APPROACH
We pay special attention to obtaining the necessary information about customers that allows us to evaluate the risk presented by each customer and to detect and report suspicious activity. When we review a customer transaction, the due diligence we perform may be in addition to customer information obtained for purposes of our KYC.For each transaction, we analyze risks, in the event there are circumstances in which we cannot perform appropriate due diligence, we will determine appropriate action including, but not limited to suspension of the transaction and/or closure of the customer’s account. It’s The Garage policy to mitigate the risks identified by each transaction.The Garage does not work with third party accounts and cash. All payments from customers to The Garage and vice versa are made through banking institutions, as well as authorized payment systems, which are guided by their own Policies when interacting with the customer.RED FLAGS, SUSPICIOUS ACTIVITY AND SUSPICIOUS TRANSACTIONSThere are signs of suspicious activity and suspicious transactions that suggest money laundering. These are commonly referred to as "red flags." If a red flag is detected, additional due diligence will be performed before proceeding with the transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the AML Compliance Committee. Examples of red flags are:● Suspicious Customer Behaviors:— overly secretive client— client refuses to provide information— client appears disinterested with outcome— client uses multiple bank accounts● Suspicious Customer Identification Circumstances:— client provides counterfeit documents— client only provides copies rather than original documents— client only provides foreign, unverifiable identity documents— client only acts through a third partyThe Garage Syndicateinfo@thegaragesyndicate.com