Monzo Capital Bank - Anti-Money Laundering (AML) Policy

1. Introduction:

Monzo Capital Bank is committed to maintaining the highest standards of integrity and compliance with applicable laws and regulations, particularly in the area of Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT). This policy outlines our commitment to preventing and detecting money laundering activities within our operations.

2. Legal Framework:

2.1. Monzo Capital Bank operates in accordance with local and international AML and CFT laws and regulations.

2.2. The AML policy complies with relevant legislation, including but not limited to the Bank Secrecy Act (BSA), USA PATRIOT Act, and other applicable regulatory requirements.

3. Customer Due Diligence (CDD):

3.1. Monzo Capital Bank conducts thorough customer due diligence before establishing a business relationship or conducting occasional transactions.

3.2. CDD includes identification verification, understanding the nature of the customer's business, and assessing the risk associated with the customer.

4. Enhanced Due Diligence (EDD):

4.1. Enhanced due diligence is applied to customers presenting a higher risk, including politically exposed persons (PEPs) and customers from high-risk jurisdictions.

4.2. Additional scrutiny is given to transactions that deviate from the established patterns or are deemed unusual.

5. Monitoring and Reporting:

5.1. Monzo Capital Bank employs advanced monitoring systems to detect and report suspicious transactions.

5.2. Employees are trained to recognize red flags and report suspicious activities promptly to the designated AML Officer.

6. Record Keeping:

6.1. Comprehensive records of customer transactions, identification information, and due diligence procedures are maintained in accordance with regulatory requirements.

6.2. Records are securely stored and made available to regulatory authorities upon request.

7. Training and Awareness:

7.1. Regular training programs are conducted for employees to ensure awareness of AML and CFT policies and the latest regulatory developments.

7.2. Employees are trained to recognize and appropriately respond to potential money laundering or terrorist financing activities.

8. AML Officer:

8.1. Monzo Capital Bank designates a qualified AML Officer responsible for overseeing the implementation and enforcement of this AML policy.

8.2. The AML Officer ensures continuous compliance with AML laws, regulations, and best practices.

9. Reporting to Authorities:

9.1. Monzo Capital Bank is committed to cooperating with law enforcement and regulatory authorities in their efforts to combat money laundering and terrorist financing.

9.2. Suspicious activities are promptly reported to the relevant authorities, and the bank collaborates fully in investigations.

10. Review and Updates:

10.1. This AML policy is subject to regular reviews to ensure its effectiveness and relevance.

10.2. Updates are made as necessary to align with changes in the regulatory environment and to enhance the bank's ability to combat money laundering and terrorist financing.

11. Communication:

11.1. This AML policy is communicated to all employees, stakeholders, and relevant third parties to ensure a collective commitment to its principles.

Monzo Capital Bank is dedicated to upholding the highest standards of integrity, transparency, and compliance with AML and CFT regulations. This policy is a testament to our commitment to combating illicit financial activities and maintaining the trust of our customers and the regulatory authorities.