ANTI TERRORISM FINANCING & PROCEEDS OF UNLAWFUL ACTIVITIES POLICY
Introduction:
- GeeksforGeeks is committed to preventing and detecting money laundering and terrorism financing activities.
- This policy outlines our procedures for identifying, reporting, and preventing suspicious transactions.
- This policy applies to all GeeksforGeeks employees, contractors, and users.
Scope:
- This policy covers all transactions and activities conducted through GeeksforGeeks platforms, services, and operations.
- This policy is applicable to all countries and jurisdictions where GeeksforGeeks operates.
Definitions:
- Money Laundering: The process of disguising the source of illicit funds to make them appear legitimate.
- Terrorism Financing: The provision or collection of funds, assets, or services to support terrorist activities.
- Suspicious Transaction: A transaction that appears unusual or suspicious, potentially related to money laundering or terrorism financing.
- Customer Due Diligence (CDD): The process of verifying the identity of users and assessing their risk profile.
- Enhanced Due Diligence (EDD): Additional CDD measures applied to high-risk users or transactions.
- Politically Exposed Person (PEP): An individual who holds or has held a prominent public position or function.
Process:
Customer Due Diligence (CDD)
- GeeksforGeeks may verify the identity of users through government-issued identification documents, utility bills, or other reliable sources.
- Users may be required to provide information about their occupation, address, and source of funds.
- GeeksforGeeks may assess the risk profile of each user based on their CDD information.
Transaction Monitoring
- GeeksforGeeks may monitor transactions for suspicious activity, including:
- Unusual patterns or volumes of transactions
- Large transactions or transactions with high-value assets
- Transactions with high-risk countries or entities
- Transactions involving PEPs or high-risk individuals
- GeeksforGeeks may use automated systems and manual reviews to detect suspicious transactions.
Reporting Suspicious Transactions
- Employees and contractors must report suspicious transactions to the disciplinary committee at GeeksforGeeks.
- The Committee will review and investigate reported suspicious transactions.
- GeeksforGeeks will file Suspicious Activity Reports (SARs) with the relevant regulatory authorities, where required.
Record Keeping
- GeeksforGeeks will maintain accurate and detailed records of transactions, customer identification, and suspicious activity reports, to the extent necessary and possible.
- Records will be kept for a minimum of five years from the date of the transaction.
Prohibited Activities
- GeeksforGeeks prohibits the use of its services for terrorism financing activities.
- We prohibit the use of our services for money laundering activities.
Employee and Contractor Responsibilities
- Employees and contractors will receive necessary training to identify and report suspicious transactions.
- Employees and contractors must report suspicious transactions to the disciplinary committee.
- Employees and contractors must maintain confidentiality when handling sensitive information.
Penalties for Non-Compliance
- Failure to comply with this policy may result in disciplinary action, up to and including termination.
- GeeksforGeeks reserves the right to suspend or terminate user accounts that violate this policy.
Policy Updates
GeeksforGeeks reserves the right to update this policy as necessary to ensure compliance with changing laws and regulations.
Acknowledgement
By using GeeksforGeeks services, users acknowledge that they have read, understood, and agree to comply with this policy.