Anti-Money Laundering & Counter-Terrorism Financing Policy
Our comprehensive framework for preventing money laundering and terrorist financing activities.
Last updated: September 10, 2025
Introduction
Riro Inc. ("Riro") is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering and Counter-Terrorism Financing (AML/CFT) Policy establishes our framework for identifying, assessing, and mitigating these risks in accordance with applicable laws and regulations.
Policy Objectives
Our AML/CFT program aims to:
- Prevent money laundering and terrorist financing activities
- Comply with all applicable AML/CFT laws and regulations
- Protect our platform and customers from financial crime
- Maintain the integrity of the financial system
- Support law enforcement investigations
- Implement risk-based compliance procedures
Risk Assessment Framework
Customer Risk Assessment
We assess customer risk based on:
- Geographic location and jurisdiction
- Customer type (individual vs. business)
- Nature of business activities
- Transaction patterns and volumes
- Source of funds and wealth
- Political exposure and sanctions status
Product and Service Risk
- Cryptocurrency conversion services
- International money transfers
- High-value transactions
- Anonymous or pseudonymous services
- Cash-intensive businesses
Risk Categories
- Low Risk: Standard monitoring procedures
- Medium Risk: Enhanced due diligence
- High Risk: Additional monitoring and controls
- Prohibited: Service denial or account closure
Customer Due Diligence (CDD)
Standard CDD
- Customer identification and verification
- Beneficial ownership identification
- Business relationship purpose assessment
- Ongoing monitoring of transactions
Enhanced Due Diligence (EDD)
- Additional identity verification
- Source of funds verification
- Enhanced transaction monitoring
- Senior management approval for high-risk customers
- More frequent account reviews
Simplified Due Diligence
- Reduced verification requirements for low-risk customers
- Streamlined onboarding process
- Basic transaction monitoring
Transaction Monitoring
We employ sophisticated transaction monitoring systems to detect suspicious activities:
Automated Monitoring
- Real-time transaction screening
- Pattern recognition algorithms
- Threshold-based alerts
- Sanctions and watchlist screening
Suspicious Activity Indicators
- Unusual transaction patterns
- High-value transactions without clear purpose
- Rapid movement of funds
- Transactions with high-risk jurisdictions
- Structuring to avoid reporting thresholds
- Use of multiple accounts or identities
Manual Review Process
- Expert analyst review of flagged transactions
- Customer behavior analysis
- Documentation and evidence gathering
- Decision on further action required
Suspicious Activity Reporting
Reporting Requirements
- File Suspicious Activity Reports (SARs) with relevant authorities
- Report within required timeframes
- Maintain confidentiality of SAR filings
- Document all reporting decisions
Internal Reporting Process
- Designated AML officer receives reports
- Investigation and analysis of suspicious activities
- Documentation of findings and decisions
- Coordination with law enforcement when necessary
Sanctions Compliance
We maintain comprehensive sanctions screening procedures:
- Real-time screening against sanctions lists
- Ongoing monitoring of customer sanctions status
- Blocking of transactions with sanctioned parties
- Reporting of sanctions matches to authorities
- Regular updates of sanctions databases
Record Keeping
We maintain comprehensive records in accordance with regulatory requirements:
- Customer identification and verification documents
- Transaction records and supporting documentation
- Risk assessments and due diligence reports
- Suspicious activity reports and investigations
- Training records and compliance certifications
- Audit trails and system logs
Training and Awareness
Employee Training
- Regular AML/CFT training programs
- Role-specific training for different functions
- Recognition of suspicious activities
- Reporting procedures and requirements
- Regulatory updates and changes
Customer Awareness
- Educational materials about AML/CFT
- Clear communication of policies
- Reporting mechanisms for suspicious activities
- Customer due diligence requirements
Governance and Oversight
Board Oversight
- Board-level AML/CFT oversight
- Regular reporting on compliance status
- Risk appetite and tolerance setting
- Resource allocation for compliance
Compliance Function
- Dedicated AML/CFT compliance officer
- Independent compliance function
- Regular risk assessments and reviews
- Internal audit and testing
Regulatory Compliance
Our AML/CFT program complies with applicable laws and regulations, including:
- Bank Secrecy Act (BSA)
- USA PATRIOT Act
- Financial Action Task Force (FATF) recommendations
- Office of Foreign Assets Control (OFAC) regulations
- Local AML/CFT laws and regulations
- International sanctions regimes
Contact Information
For questions about our AML/CFT policy or to report suspicious activities:
AML Officer: austine@riromonie.com
Compliance: austine@riromonie.com
Address: Riro Inc., 8 The Green, Ste A, in the City of Dover County, Delaware, USA.
Phone: +234 813 457 9812