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Anti-Money Laundering Manual

Anti-Money Laundering and Counter-Terrorism Financing Compliance Manual

Section I: Introduction

Section II: Applicable Laws

Section III: Products and Services

Section IV: Compliance Officer

Section V: Customer/Counter Party Due Dilgence (CDD), Know-Your-Customer/Know-Your Counter Party (KYC) and Customer/Counter Party Identification (CIP) Program

Section VI: Procedures for the Establishment of New Relationships

Section VII: Risk Assessment

Section VIII: Monitoring and Suspicious Activitiy Reporting

Section IX: Implementation of New Products and Technologies

Section X: Independing Testing of the AmL/CFT Compliance Program

Section XI: Training

Section XII: Compliance Functions

Section XIII: Know Your Employee

Exhibits

Section I: Introduction

A. General Statement of Purpose

Scrapabill Management Ltd, Scrapabill Inc. ("Scrapabill") is committed to a safe and sound practice. It is the policy of Scrapabill to comply with all material regarding applicable anti-money laundering and counter-terrorist financing (AML/CFT) laws, regulations, guidelines and norms, including but not limited to:

Proceeds of Crime (Money Laundering and Terrorist Financing Act (PCMLTFA) S.C. 2000, C 17, S 9.6 (1)
Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 156(1) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(a) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(b) (as will be amended when SOR/2019-240 comes into force).
PCMLTFA, S.C. 2000, c 17, s. 9.6(2).
PCMLTFR, SOR/2002-184, s. 156(1)(c) (as will be amended when SOR/2020-112 comes into force).
PCMLTFR, SOR/2002-184, s. 156(2) (as will be amended when SOR/2020-112 comes into force).
PCMLTFA, S.C. 2000, c 17, s. 9.6(3).
PCMLTFR, SOR/2002-184, s. 157 (as will be amended when SOR/2020-112 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(d) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(e) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(3) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(f) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(4) (as will be amended when SOR/2019-240 comes into force).

This Anti-Money Laundering and Counter Terrorist Financing (AML/CFT) Compliance Manual has been developed in a dual role. One, it is designed to address related compliance issues pertaining to EEUU and Canada, and the other is to also address issues relevant to U.S or Canada. Compliance-related requirements. The primary objectives and goals of the AML/CFT Manual (or AML/CFT Program, as implemented through this BSA/AML/OFAC Compliance Manual, are the following:

Prevent the use of the Company by criminals to further illegal/illicit activities of any type, including money laundering and terrorist financing.
Provide comprehensive procedures and internal controls to be observed in order to ensure that the Company is in full compliance with the BSA, all applicable anti-money laundering federal and state laws, regulations and norms, as well as all economic and trade sanctions and requirements of the OFAC regulations.
Develop and implement policies, procedures and systems to ensure the detection and reporting of any suspicious activity passing through the Company.
Define the BSA/AML/OFAC compliance responsibilities of the Company’s AML Compliance Officer.
Define the monitoring activities of the Company to ensure that the policies and procedures developed and adopted in this AML/CFT Compliance Manual are being effectively implemented.
Ensure the revision and update of the AML/CFT Compliance Manual to guarantee that any changes in the applicable laws, regulations and/or policies and procedures are noted and incorporated into the AML/CFT Compliance Manual, thus ensuring it is always up to date.
Ensure that all personnel at the Company are adequately trained on a regular basis and are fully aware of the applicable laws and regulations that are critical to the performance of their assigned duties.
Test the effectiveness of the AML/CFT Compliance Manual through audits conducted by independent auditors.
Promptly identify and resolve any BSA/AML/OFAC deficiencies and problems to preclude regulatory enforcement actions.
Avoid civil or criminal liability due to non-compliance.

B. Background

Scrapabill Management Ltd is a company registered under the laws of Canada and also conducts business in the United States of America and worldwide. It is registered as Scrapabill Inc. in the State of Wyoming, USA. The Scrapabill’s Corporate Office is located in the Suite 429 - 1275 West 6th Avenue Vancouver, British Columbia, V6H 1A6, Canada. The integrity of Scrapabill may be undermined by the threat of money laundering and terrorist financing. Those who launder money and finance terrorism may attempt to use Scrapabill and other financial institutions as attractive conduits for the concealment of the true source of their funds.

At Scrapabill, we have recognized that one of the most effective ways of deterring and identifying criminal activity is by taking reasonable steps to “Know Your Customer” (KYC) when establishing business relationships coupled with ongoing monitoring of existing customer files and arrangements. As a result, the board has adopted this policy and developed a “Know Your Customer Policy” which is intended to:

Establish basic rules which when applied will enable staff to detect and prevent any attempt by a third party to use the services and products of Scrapabill for illegal activities;
To promote full adherence and compliance with Anti Money Laundering and Counter Financing of Terrorism applicable laws, international standards and best practices in the industry.
To provide the mechanism through which Scrapabill will assist the regulatory authorities in their anti-money laundering and counter financing of terrorism efforts.

C. General Statement of Purpose

Scrapabill is committed to a safe and sound Scrapabill practice. It is the policy of Scrapabill to comply in all material respects with applicable anti-money laundering and counter-terrorist financing (AML/CFT) laws, regulations, guidelines and norms, including but not limited to:

Proceeds of Crime (Money Laundering and Terrorist Financing Act (PCMLTFA) S.C. 2000, C 17, S 9.6 (1)
Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 156(1) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(a) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(b) (as will be amended when SOR/2019-240 comes into force).
PCMLTFA, S.C. 2000, c 17, s. 9.6(2).
PCMLTFR, SOR/2002-184, s. 156(1)(c) (as will be amended when SOR/2020-112 comes into force).
PCMLTFR, SOR/2002-184, s. 156(2) (as will be amended when SOR/2020-112 comes into force).
PCMLTFA, S.C. 2000, c 17, s. 9.6(3).
PCMLTFR, SOR/2002-184, s. 157 (as will be amended when SOR/2020-112 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(d) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(e) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(3) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(1)(f) (as will be amended when SOR/2019-240 comes into force).
PCMLTFR, SOR/2002-184, s. 156(4) (as will be amended when SOR/2019-240 comes into force).

D. What is Money Laundering?

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origin of criminally derived proceeds so that the unlawful proceeds appear to have derived from legitimate origins or constitute legitimate assets. All financial institutions could be the target of organized crime, particularly money laundering. Although money laundering is a diverse and often complex process, it basically involves three independent steps:

Placement: The process of placing, through deposits or other means, cash proceeds of illegal activities into traditional financial institutions.

Layering: The process of separating the proceeds of criminal activity from their origin through the use of layers of complex financial transactions in order to further disguise the origins and ownership of the funds. Examples include converting cash into traveler’s checks, money orders, wire transfers, letters of credit, stocks, bonds, or purchasing valuable assets such as art or jewelry designed to disguise the origins and ownership of the funds in order to hide the origin of the cash and the ownership of the funds.

Integration: The process of using an apparently legitimate transaction to place the proceeds back into the financial system thus allowing the laundered funds to be returned back to the criminal. For example: cash is deposited into an account for a legitimate business and commingled with the cash receipts of the business. The business enterprise requires significant volume to justify the amount of cash.

E. References to Anti-Money Laundering and Counter-Terrorist Financing Compliance Manual; Rules of Constructions

This Manual contains policies and procedures to Scrapabill’s Products and Services, there may be other policies, procedures or internal controls adopted and/or implemented by Scrapabill from time to time, including Scrapabill’s Office of Foreign Assets Control (OFAC)/Sanctions Compliance Manual (the OFAC/Sanctions Manual or OFAC/Sanctions Program) that may be relevant to or impose additional requirements relating to the Manual. In light of the foregoing, the following rules of construction shall apply to the Manual:

The Manual has been adopted by Scrapabill pursuant to the approval of Scrapabill’s Board and shall take effect as of July 1st, 2021 (the Effective Date);
The Manual applies to Scrapabill and its directors, officers and employees;
Compliance with this Manual is a condition of employment for all Scrapabill directors, officers, employees. Independent contractors, etc.
All Scrapabill directors, officers and employees, active role in preventing the use of Scrapabill and the cash support social networking services for illegal/illicit activity.
Scrapabill directors, officers, independent contractors, and employees violating this Manual or any applicable AML/CFT laws may be subject to disciplinary action, up to and including termination;
Also, as a condition of employment, all Scrapabill directors, officers and employees agree not to reproduce, disseminate the information contained herein, or copy it by any means whatsoever, nor to permit such actions by others, for any purpose, without the written consent of the Scrapabill;
For avoidance of doubt, each reference to the "Manual," "hereunder," "hereof," "herein" or words of like import in this Manual, or in any other agreements, documents, or instruments executed and delivered pursuant to, or in connection with, this Manual, shall mean and be a reference to this Manual as amended, modified and supplemented from time to time;
Nothing expressed or implied in this Manual is intended, or shall be construed, to confer upon or give any person other than Scrapabill and its respective legal representatives, successors and permitted assigns, any rights or remedies under or by reason of this Manual;
Scrapabill reserves the right to amend, modify or supplement this Manual from time to time; and
This Manual is owned and copyrighted by Scrapabill.

All inquiries concerning this Manual and/or the AML/CFT laws discussed herein should be directed to Scrapabill’s Compliance Officer at: info @ scrapabill.com or by Phone: +1.604.256.9333

Section II: Applicable Laws

Policy Statement

It is Scrapabill’s policy to observe and implement applicable guidelines and requirements governing anti-money laundering, combating terrorist financing, and related legislation.

A. Listing of applicable laws and regulations

Fintrac

i. https://www.fintrac-canafe.gc.ca/guidance-directives/compliance-conformite/Guide4/4-en

Money Laundering (Prevention) Act

i. Proceeds of Crime (Money Laundering and Terrorist Financing Act (PCMLTFA) S.C. 2000, C 17, S 9.6 (1)

Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFR), SOR/2002-184, s. 156(1) (as will be amended when SOR/2019-240 comes into force).

PCMLTFR, SOR/2002-184, s. 156(1)(a) (as will be amended when SOR/2019-240 comes into force).

PCMLTFR, SOR/2002-184, s. 156(1)(b) (as will be amended when SOR/2019-240 comes into force).

PCMLTFA, S.C. 2000, c 17, s. 9.6(2).

PCMLTFR, SOR/2002-184, s. 156(1)(c) (as will be amended when SOR/2020-112 comes into force).

PCMLTFR, SOR/2002-184, s. 156(2) (as will be amended when SOR/2020-112 comes into force).

PCMLTFA, S.C. 2000, c 17, s. 9.6(3).

PCMLTFR, SOR/2002-184, s. 157 (as will be amended when SOR/2020-112 comes into force).

PCMLTFR, SOR/2002-184, s. 156(1)(d) (as will be amended when SOR/2019-240 comes into force).

PCMLTFR, SOR/2002-184, s. 156(1)(e) (as will be amended when SOR/2019-240 comes into force).

PCMLTFR, SOR/2002-184, s. 156(3) (as will be amended when SOR/2019-240 comes into force).

PCMLTFR, SOR/2002-184, s. 156(1)(f) (as will be amended when SOR/2019-240 comes into force).

PCMLTFR, SOR/2002-184, s. 156(4) (as will be amended when SOR/2019-240 comes into force).

Section III: Products and Services

Policy Statement

It is Scrapabill ’s policy to implement and maintain a AML/CFT Program intended to enable Scrapabill to prevent and detect suspected illegal/illicit activity occurring and/or effected through Scrapabill products and services, including money laundering, terrorist financing and violations of Sanctions.

It is the policy of Scrapabill to comply with all applicable AML/CFT and Sanctions Laws.

Scrapabill offers its customers certain products and services, which may include the following:

Business Model

Scrapabill is an online social platform where people meet, interact, and tell financial stories to get cash support for bills and debts. People from different cultures, both home and abroad, will use Scrapabill to give and receive cash support to cover household and business expenses. Scrapabill shall introduce additional online products and services with unique features and capabilities, such as Scrapabill for business, ride, technology, and food in the future.

A. Scrapabill Online Platform

Scrapabill’s platform provides limited products and services. The customers may perform the following activities:

Follow other users bills on the platform to give cash support.
Top-up and enter bills to receive cash support from friends, family members and associates on the Scrapabill platform.
Make a withdraw request.
Pay bills to avoid penalties.

How it Works

Research shows that over 1 billion invoices are issued daily worldwide, so users will enter bills one at a time. When friends follow you, the support amount gets added to your active bill support account until the bill scraps.

Here are the five easy steps to Scrapabill: Follow Bill --> Enter Bill --> Get Support --> Withdraw Funds --> Pay Bill

Why Scrapabill

Get community support when in financial need. Use Scrapabill to pay off your bills and debts quickly. Want more practical reasons to Scrapabill?

Bills Never End

Over 1 billion invoices are issued daily worldwide. Paying bills is a part of life.

Overcome Debt Overload

Overcome stress, fear, depression, or anxiety from cycles of bills and debt overload.

Make Life Enjoyable

Scrap bills regularly with your neighbor and enjoy life with the extra savings.

Grow Your Network

Anyone living around you or abroad can willingly and faithfully join your bill support network.

With safety and security in mind, Scrapabill presents you with modern features.

Instant Alert
Meet Friends
ID Verification
Manage Profile
Check Balance
Support E-wallet
GDPR Compliance
Track Transactions

Section IV: Compliance Officer

Scrapabill has designated Mr. Jose Torrealba as its Chief Compliance Officer (CCO). The Chief Compliance Officer is responsible for coordinating and ensuring compliance with this Manual by Scrapabill's employees. In doing so, the CCO may delegate duties to other employees, outside counsel or consultants, but will, at all times, remain responsible for the Scrapabill ’s compliance with this Manual. In addition to such other duties and responsibilities referenced in other sections of this Card Services Manual, as well as the AML/CFT Manual or the Sanctions Manual, the Compliance Officer has been assigned the following duties and responsibilities:

Administer Scrapabill’s AML/CFT Program;
Develop a system of internal controls to provide accountability for assets;
Oversee that all areas/departments of Scrapabill observe the policies, procedures and controls established to comply with applicable AML/CFT and Sanctions laws;
Support management and staff in their efforts to ensure that Scrapabill is in compliance with applicable AML/CFT and Sanctions laws;
Investigate all instances of known or suspected illegal/illicit activities and, where necessary, take or recommend responsive action in accordance with this Manual;
Prepare, or cause to be prepared, and file any reports required to comply with applicable AML/CFT and Sanctions laws;
Maintain and update this Manual as necessary to ensure that it accurately reflects any changes in applicable AML/CFT laws;
Update Scrapabill forms, documents and notices in order to comply with existing requirements under applicable AML/CFT laws;
Collect and retain all requisite information/documentation for the record-retention period(s) set forth in this Manual;
Communicate the policies and procedures set forth in this Manual to all relevant Scrapabill personnel;
Institute an on-going training and testing program for key Scrapabill employees to provide comprehensive and up to date education on applicable AML/CFT laws that affect the Scrapabill ’s Services and the tasks performed by those employees;
Encourage Scrapabill employees to communicate any compliance concerns or questions and, in particular, establish and maintain methods for employees to report suspected illegal/illicit activity in an anonymous manner;
Research and respond to any compliance questions from Scrapabill personnel, using the Scrapabill ’s compliance regulatory reference materials, regulatory agencies, compliance consultants, and outside counsel, as appropriate;
Coordinate with regulatory agencies during examinations or investigations, as required by applicable law, furnish examiners/investigators with requested information, and act as primary examination contact;
Assist Scrapabill’s auditors and independent compliance reviewers by providing documents, reports and any other compliance information as may be required during the course of an audit or review;
Take necessary action to coordinate and oversee the correction of violations and deficiencies noted during audits, compliance reviews, and/or regulatory examinations;
Remain up-to-date on all applicable AML/CFT issues by regularly reviewing the websites of applicable regulatory agencies, other government and non-governmental websites, relevant news sources, professional sources, and other sources of information;
Serve as a liaison to Scrapabill’s Compliance Committee by regularly apprising the Compliance Committee of Scrapabill’s ongoing compliance with applicable AML/CFT laws; and
Carrying out the direction of the Board as it relates to this Manual.

Section V: Customer/Counter Party Due Dilgence (CDD), Know-Your-Customer/Know-Your Counter Party (KYC) and Customer/Counter Party Identifcation (CIP) Program

A. CDD/KYC Program

Scrapabill is committed to preventing the use of Scrapabill’s products and services as a vehicle for any form of illegal/illicit activity. One of the most successful ways in which Scrapabill can protect itself from serving as a conduit for illegal/illicit activity is by acquiring information about its customers and counterparties, utilizing a risk- based approach that will permit the detection of unusual or suspicious activity. To that end, Scrapabill has developed a KYC/DD policy with the following objectives:

To enable Scrapabill to obtain adequate knowledge of the true identity of each of its customer and counterparties.
To enable Scrapabill to verify the identity of its new customer to the extent reasonable and practicable;
To enable Scrapabill to monitor activity in order to prevent and detect illegal/illicit activity or suspicious transactions that potentially expose the Scrapabill to financial loss, increased expenses or reputational risk; and
To ensure that Scrapabill is in compliance with applicable AML/CFT Laws.

Policy Statement

It is the policy of Scrapabill to perform reasonable, risk-based due diligence on its customers prior to engaging in any business relationship.

It is the Scrapabill ’s policy to maintain an effective level of internal controls designed to mitigate AML/CFT related risks in line with the products and services. Scrapabill will apply a Customer Identification Program (CIF), Know Your Customer (KYC) policy and Customer Due Diligence/Enhanced Due Diligence (CDD/EDD), as required.

B. CIP Program

It is Scrapabill’s policy to implement and maintain an effective methodology to identify and monitor the individuals and corporations that conforms the Scrapabill ’s customer base. In addition to the foregoing, Scrapabill has developed and implemented a written CIP. The CIP is an integral part of the Scrapabill ’s AML/CFT Program and enables Scrapabill to form a reasonable belief that it knows the true identity of each of its customers and counterparties. The CIP is based upon the Scrapabill ’s assessment of the relevant risks, including risks presented by: (1) the products and services offered by Scrapabill; (2) the various methods of opening or establishing relationship with the Scrapabill ; and (3) the various types of identifying information available.

Scrapabill’s CIP is intended to, among other things:

Obtain information to establish the true identity of any individual/entity that establishes a relationship with Scrapabill;
Verify the identity of such person, to the extent reasonable and practicable;
Maintain records of the information used to verify the person/entity's identity,
including name, address and other identifying information; and
Determine whether the person/entity appears on any list of known or suspected terrorists or terrorist organizations provided to the financial
institution by any government agency.

Scrapabill utilizes risk-based procedures for verifying the identity of each customer, these procedures enable the Scrapabill to have a reasonable belief that it knows the true identity of the customers.

Policy Statement

It is Scrapabill’s policy not to establish a relationship until all required CIP information is obtained and verified.

C. Anonymous activity:

Policy Statement

It is the Scrapabill’s policy not to maintain anonymous accounts and/or products.

It is Scrapabill’s policy to prohibit the establishment of anonymous accounts or provide any anonymous products; policies and procedures in place reasonably ensure Scrapabill's adherence to this prohibition. To deter anonymous activity with respect to the products issued by Scrapabill, Scrapabill has made it a policy not to maintain anonymous accounts and to require that prior to the acceptance of a customer, the identity of the potential customer will be obtained and verified in accordance with the policies and procedures in this Manual.

Policy Statement

Prior to the issuance, it is the Scrapabill ’s policy to obtain and verify the identity of the customer in accordance with the Scrapabill ’s policies and procedures.

D. Politically Exposed Person (PEPs)

Scapabill defines a Politically Exposed Person (PEP) as any individual who is or has been entrusted with prominent public functions in a foreign country, including a Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials, including family members or close associates of the politically exposed person.

Scrapabill has no interest in opening accounts to politically exposed persons (PEP). Nevertheless, in exceptional cases, The Scrapabill may open a PEP account only when the Compliance Committee has approved the opening of an account for that particular individual. All PEPs accounts will be subject to an Enhanced Due Diligence.

Section VI: Procedures for the Establishment of New Relationship

A. Defined Terms

For purposes of this Section VI, the following terms shall have the meanings ascribed below:

“Business Customer” means the entity (e.g., a corporation, a partnership, a trust or estate, a joint stock company, an association, a syndicate, joint venture, or other unincorporated organization or group) that intends to obtain a product issued by the Scrapabill in the entity’s name.
“Account Holder” means the authorized user of an account opened by Scrapabill after the Effective Date pursuant to the General Terms and Conditions.
“Customer” means an Individual Customer or Business Customer, as applicable that maintains a product with the Scrapabill..
“Covered Relationship” means any commercial relationship maintained by the Scrapabill after the Effective Date with a Counterparty.
“Individual Customer” means the natural person that intends to obtain a product offered and/or issued by Scrapabill in the individual’s name, which, in the case of prepaid or virtual Cards, may be the owner of the funds on the Card.
“Potential Customer” means any person that apply to obtain a product or service offered by Scrapabill.

B. General Procedures for the Establishment of New Covered Relationships

In addition to any other policies and procedures required pursuant to the AML/CFT Manual or the Sanctions Manual, the following procedures must be observed prior to the establishment of all Covered Relationships established after the Effective Date:

For all Covered Relationships with Customers, Accountholder, Cardholders or Covered Relationship, the Account Representative must obtain and review all documents depending on the type of relationship being established, and ensure that all required documents/information have been obtained from, and properly completed and signed, as applicable, by the Potencial Customer, including:

Purpose of the account.
Expected activity through the Account.
Completed account application forms and account opening documentation (KYC/CDD).
Description of the business.

All such documentation/information enumerated in Exhibit 1 shall be submitted or uploaded electronically by the Account Representative. A relevant member of the Compliance Department (designed by the Chief Compliance Officer or Head of Compliance) will confirm that CIP procedures set forth in Section VI have been properly completed. The Compliance Officer will complete the CDD/KYC risk rating for the prospective Customer utilizing the risk rating matrices www.getmati.com.

Verification/Background Review (All Covered Relationships) Prior to the establishment of all new Covered Relationships, the Assistant Compliance Officer or other member of the Scrapabill ’s Compliance Department designated by the Compliance Officer shall:

Conduct a search for the Counterparty utilizing www.getmati.com and a search engine (such as Google, Bing or Yahoo) in order to ensure that there is not any publicly available information on the Counterparty or Potencial Customer that would adversely affect the Scrapabill ’s decision to establish a relationship for such prospective Counterparty. In the case of an individual Counterparty, the verification/background review must be performed on the individual. In the case of a Counterparty that is a legal person, the verification/background review must be performed on the entity, beneficial owners (5% or more), senior officers, directors, attorneys-in-fact or other persons with authority to provide the Scrapabill with instructions in connection with the Covered Relationship per Scrapabill ’s records. If applicable, a print-out of the registration/licensing of the prospective Counterparty should be obtained.

If any such negative information is detected, the Assistant Compliance Officer or relevant member of Scrapabill’s Compliance Department shall promptly notify the Compliance Officer of same and a printout or electronic copy of the search shall be retained in the Scrapabill ’s records.

OFAC/Section 311 Check. Prior to establishing a new Covered Relationship, the Assistant Compliance Officer or other member of the Scrapabill ’s Compliance Department designated by the Compliance Officer shall:

Conduct an OFAC/Section 311 check through the World Check to verify that the name of the Counterparty does not appear on an OFAC list of specially designated nationals, narcotics traffickers or terrorists, and/or any list of persons and/or entities subject to Section 311 sanctions. In the case of a Counterparty that is a legal person, the OFAC/Section 311 Check will be performed on the entity, beneficial owners (5% or more), senior officers, directors, attorneys-in- fact or other persons with authority to provide the Scrapabill with instructions in connection with the Covered Relationship per Scrapabill’s records.
A printout or electronic copy of the search shall be retained in the Scrapabill ’s records.
All resolutions of potential OFAC matches shall be clearly documented.
If the Counterparty’s name (or any other persons searched) matches a name appearing on any of the above lists, the Assistant Compliance Officer or the relevant member of the Scrapabill ’s Compliance Department shall notify the Compliance Officer immediately, and the Covered Relationship SHALL NOT BE OPENED
Refer to the Sanctions Manual for additional Sanctions procedures.

Identification of Politically Exposed Persons (PEPs)

Prior to establishing a new Covered Relationship, the Assistant Compliance Officer or a member of Scrapabill’s Compliance Department designated by the Compliance Officer shall:

Determine, by running searches through www.getmati.com and a search engine (such as Google, Bing or Yahoo)], whether the beneficial owners (5% or more), senior officers, directors, attorneys- in-fact or other persons with authority to provide the Scrapabill with instructions in connection with the Covered Relationship per the Scrapabill ’s records is a PEP or an immediate family member/close associate of a PEP.
If it is determined that any of these may be a PEP, the Assistant Compliance Officer or the relevant member of the Scrapabill ’s Compliance Department shall promptly notify the Chief Compliance Officer and SHALL NOT ESTABLISH THE COVERED RELATIONSHIP.
If the Counterparty appears to be a PEP or an immediate family member/close associate of a PEP, the Enhanced Due Diligence internal controls specified in the AML/CFT Manual shall be followed. If the Compliance Officer finds that the Counterparty is a PEP or an immediate family member/close associate of a PEP, a Covered Relationship will not be established with the Counterparty without the approval of the Board of Directors.

Policy Statement

It is the Scrapabill ’s policy to regularly conduct appropriate due diligence to ascertain whether a new or existing Counterparty is a Politically Exposed Person (PEP).

Scrapabill will adhere to the OFAC policies and procedures set forth in Section V(D), Section V(E) and Section V(F) of the Sanctions Manual.

The Chief Compliance Officer or the Assistant Compliance Officer shall review all information/documentation obtained for each new Covered Relationship to ensure that all required information/documentation has been completed and reviewed for suspicious activity monitoring purposes. If any information is missing, the Compliance Officer or the Assistant Compliance Officers shall promptly notify the Account Representative to resolve noted deficiencies.
If any suspicious activity is detected, the Account Representative or relevant member of the Scrapabill’s Private Department, as applicable, shall refer the prospective Counterparty to the Compliance Department who shall determine whether the new Covered Relationship should be opened and/or closed and whether a suspicious activity report (SAR), if appropriate, should be filed. [Refer to Section VIII for additional SAR procedures.]
If the Compliance Officer verifies that all information/documentation is complete and approves the establishment of the Covered Relationship, the Covered Relationship shall be subjected to Scrapabill ’s other operational procedures.
The Compliance Officer shall be responsible for ensuring that the Scrapabill complies with the applicable recordkeeping/retention requirements pertaining to account-opening information/documentation.

A. CIP Procedures

Notice to Counterparties.

To the extent required by applicable AML/CFT law, Scrapabill will provide its Counterparties and/or Potential Customers with adequate notice that it is requesting information to verify their identities.

Procedures for Obtaining Identity Information of Counterparties.

The Account Representative must obtain and retain the following identification information from the prospective Counterparty prior to establishing any Covered Relationship with such Counterparty and/or Potential Customer

Full name (full legal name as found on government issued documents such as driver’s license, passport, birth certificate, or social security card. For legal entities, the full legal name as found on an organizational document).
- Date of birth (only for individuals; can be verified through driver’s license, passport, credit report, or other official document).
- Address
  - For an individuals, a residential address must be the permanent home street address. Business address should not be recorded for a Card held in the name of Individuals.
  - For a legal entity, a principal place of business, local office, or other physical location.
  - In both instances (individuals and legal entities), a P.O. Box or postal drop is not acceptable as the sole address on record.
  - In both cases, the Scrapabill might accept an updated account statement and Tax Register as a valid proof of address.
- Identification Number
  - For a U.S or Canada. citizen, permanent resident alien or entity organized under the laws of the U.S. or Canada, a social security number or taxpayer identification number (e.g., EIN). No “awaiting TIN status” will be accepted.
  - For a non-resident alien or entity organized under the laws of a non-U.S or Non-Canada. jurisdiction, taxpayer identification number, passport number/country of issue, alien registration card, or number and country of issue of another governmentally issued photo identification.

In addition to gathering the identity information described in Section VI above, the Account Representative must obtain, review and retain a copy of the documents described below in order to verify the identification information received from the Counterparty during the establishment of the Covered Relationship. In doing so, the Scrapabill may rely on documentary or non-documentary methods to verify the Counterparty’s identity.

Procedures for Documentary Verification of Identity Information of Counterparties.

Generally, each Potential Customer that establishes a new Covered Relationship with Scrapabill must verify its identity through appropriate documentation. A copy of the documentation used to verify the identity of the Counterparty must be kept in Scrapabill ’s records. The documentary methods to be used by Scrapabill to verify the identity of an individual Counterparty include review of an unexpired government-issued photo identification, such as a passport, national identity card, driver’s license, or a combination of other unexpired documents, with the Counterparty’s name and address and a photograph of the Counterparty.

For an entity Counterparty, the documentary methods for identify verification include review of pertinent organizational documents (e.g., articles of incorporation or organization, partnership agreement, etc.), any amendments thereto, and (if applicable) a certificate of good standing issued by the state of incorporation or formation of the prospective Counterparty.

Procedures for Non-Documentary Verification of Identity Information of Counterparties.

Although it is the specific policy of Scrapabill to effectuate verification of identity information through documents, Scrapabill may, where appropriate and utilizing a risk-based approach, use non- documentary methods of verification in addition to relying on documents. Because identification documents may be obtained illegally or fraudulently, Scrapabill shall effectuate the use of non- documentary methods in accordance with a risk-based approach.

Non-documentary methods may include

Contacting/interviewing a Counterparty;
- Independently verifying the Counterparty's identity through the comparison of information provided by the Counterparty with information obtained from a consumer reporting agency, public database, or other source;
- Checking references with financial institutions or business peers; and
- Obtaining a financial statement from the Counterparty.

Record Retention applicable to CIP

Scrapabill will retain CIP information/documentation obtained at the establishment of a new Covered Relationship for five (5) years from the date a Covered Relationship terminates (if not terminated, the date of the last transaction with the Covered Relationship).

Section VII: Risk Assessment

A. General Policy Applicable to Risk Assessment

Scrapabill shall periodically assess the AML/CFT and Sanctions risks associated with the Scrapabill services. For purposes of making the risk assessment (the Risk Assessment), Scrapabill shall take into account all relevant factors including, but not limited to:

Any changes in Scrapabill ’s operations or the Services;
The type(s) of services that the Scrapabill may offer, as well as the nature of customers, suppliers, distribution channels, and geographic locations relevant to such services;
The extent to which Scrapabill engages in transactions other than with established customers or suppliers
Whether the service contemplate transactions originated or destined for jurisdictions: (1) subject to Sanctions (the Balkans region, Belarus, Burundi, Central African Republic, the Crimea region of Ukraine, Cuba, Democratic Republic of the Congo, Iran, Iraq, Lebanon, Libya, North Korea, Russia, Somalia, South Sudan, Sudan, Syria, Venezuela, Yemen and Zimbabwe); (2) identified by the U.S. Department of State as a sponsor of international terrorism under 22 U.S.C. S. 2371; (3) designated as non-cooperative with international anti-money laundering principles or procedures by an intergovernmental group or organization of which the U.S. is a member and with which designation the U.S. representative or organization concurs; or (4) designated by the Secretary of the U.S. Department of the Treasury pursuant to 31 U.S.C. S. 5318A as warranting special measures due to money laundering concerns; and
Any developments in applicable AML/CFT and Sanctions laws.

It is Scrapabill's policy to develop, implement, and maintain an effective level of internal controls designed to mitigate AML-related risks in line with its Risk Profile, as determined by its AML/CFT Risk Assessment. This policy is applied by Scrapabill according to its size, customer base, products, services and geographic location.

A fundamental element of Scrapabill’s AML/CFT Program should be the assessment of the customer base, product lines, nature of transactions, and identification of high-risk geographic areas of money laundering and terrorist- related transactions.

Prior to launching a new product or service, or targeting a new customer or geographic market, a risk assessment should be performed. The Chief Compliance Officer or designated member in the Compliance Department, in conjunction with Scrapabill’s appropriate management, should conduct and maintain an appropriate written assessment of the AML/CFT risks present for Scrapabill in light of its products and services, customer base, and geographic markets. The risk assessment should also identify the high-risk geographic areas in which Scrapabill does business.

Regardless of where risks arise, Scrapabill shall take reasonable, risk-based measures to manage these risks and will focus resources on the areas of its business that pose the greatest risks.

Policy Statement

It is Scrapabill’s policy to conduct a periodic Risk Assessment to assist Scrapabill in effectively identifying and managing AML/CFT and Sanctions risks among Scrapabill's products and services.

B. Periodic Risk Assessment Procedures

On a periodic basis, Scrapabill shall conduct a Risk Assessment or alternatively, engage a qualified, independent third party to perform the Risk Assessment across the organization.
The Chief Compliance Officer shall ensure that the scope and methodology for the Risk Assessment is appropriate, complete and risk based.
The Chief Compliance Officer will ensure that Scrapabill maintains copies of the Risk Assessment for a period of five (5) years from the date of issuance of such assessment, and that such assessment is readily available upon request.
The Chief Compliance Officer shall review Risk Assessment concurrently with the Compliance Committee and Scrapabill’s senior management and determine whether any corrective action, mitigating steps or improvements need to be taken in response to the Risk Assessment, including, amending the Manual. In evaluating what remedial measures may be necessary, the Chief Compliance Officer may confer with the Compliance Committee and Scrapabill ’s senior management.
Upon completion of such review by the Chief Compliance Officer, the Risk Assessment shall be presented to the Compliance Committee for their review, together with any remedial measures proposed by the Chief Compliance Officer.
Upon review of the Risk Assessment and the remedial measures proposed by the Chief Compliance Officer (if any), the Compliance Committee shall consent to, authorize, ratify and/or approve the Card Services Risk Assessment and the implementation of the remedial measures, provided that the Compliance Committee may require additional enhancements thereto.
Thereafter, the Compliance Committee will ensure that the remedial measures are implemented on a timely basis by the Scrapabill ’s senior management, including the Chief Compliance Officer.

Although any type of account is potentially vulnerable to money laundering or terrorist financing, by the nature of their business, occupation, or anticipated transaction activity, certain customers and entities may pose specific money laundering risks and might require and frequently re-assessment:

Foreign financial institutions, including Scrapabill s and foreign money services providers (e.g., exchange houses, money transmitters, and bureau de change).
Non-Scrapabill financial institutions (e.g., money services businesses, casinos and card clubs, brokers/dealers in securities, and dealers in precious metals, stones or jewels).
Senior foreign political figures and their immediate family members and close associates (collectively known as politically exposed persons (PEPs).
Foreign corporations with transaction accounts.
Deposit brokers, particularly foreign deposit brokers.
Cash-intensive businesses (e.g., convenience stores, restaurants, retail stores, liquor stores, cigarette distributors, vending machine operators, and parking garages).
Non-governmental organizations and charities.
Professional service providers (e.g., attorneys, accountants, doctors, or real estate brokers)

C. Risk Level

Scrapabill’s management recognizes that attempts to launder money, finance terrorism, or conduct illegal activity through Scrapabill’s services can emanate from many different sources. Certain client types and characteristics (products and services used, geographic locations, etc.) may expose Scrapabill to higher risk of abuse by money launderers and criminals. Establishing a reasonable risk rating program for Customers and their associated products a is a critical tool in the fight against money laundering and other types of criminal behavior. Scrapabill’s risk rating methodology for Customers (the Risk Rating Methodology) has been developed and established in accordance with regulatory guidance. Scrapabill has chosen the following criteria to evaluate the risk level of each client and their associated accounts:

Relationship/Account Type;
Domicile (Individual);
Occupation/Nature of Business;
Products and Services Used;
Inclusion on Scrapabill’s Watch List;
Duration of Client Relationship;
Entity Type (Prepaid payroll cards only: Employer entity type);
Jurisdictions where activities or business conducted by employer (Individuals and Entities);
Politically Exposed Person (PEP);
Beneficial Owners (5% or more), trustees, senior officers, directors, attorneys-in-fact or other persons with authority to provide the Scrapabill with instructions in connection with the account;
Subjective Risk Assessment.

Scrapabill employs a manual process to evaluate the relative risk of each client. Each client is assigned a relative risk rating for each of the aforementioned criteria on the appropriate Customer Risk Rating Matrix. Using the Scrapabill’s platform systems and KYC repository, a risk score is assigned to each client based upon specific risk variables regarding client characteristics, products, services, geographical locations, and transactional volumes.

Scrapabill has created a matrix for assigning points to clients based upon the level of risk in each of the categories listed above. The matrix applies a point value within each risk category based upon the inherent characteristics of each client and their actual. Points for each client are accumulated and applied against a table to determine the overall level of risk for each client. The Scrapabill’s Services AML/CFT Program is based upon an assessment of the AML/CFT risks to which Scrapabill is exposed due to its size, customer base, products, services and geographic location. Relying on such risk assessment, Scrapabill’s AML/CFT Program seeks to adequately monitor, control, and mitigate Scrapabill’s AML/CFT risks with respect to Scrapabill services.

All Customers will be risk rated before the account opened using Scrapabill’s Risk Rating Methodology. The Customer risk assessment methodology allows the Scrapabill to consider various risk factors applicable to Scrapabill and a particular customer, and to categorize each customer as low, moderate, or high risk for money laundering or terrorist financing. A copy of the completed Customer Risk Rating Matrix will be maintained in the Scrapabill ’s records.

The assigned risk rating is a reflection of the relative risk exposure to money laundering and terrorism financing. The Customer risk assessment in conjunction with CDD/KYC/CIP information helps Scrapabill to develop an understanding of normal and expected activity for the Customer. This information is used to help the Scrapabill differentiate between lower risk customers and higher risk customers at on-boarding.

With respect to accounts that have been identified by Scrapabill's CDD procedures as posing a heightened risk, these accounts should be subjected to enhanced due diligence (EDD) that is reasonably designed to enable compliance with the requirements of the BSA.

The required EDD may include but is not limited to:

Financial statements;
Source of wealth/funds; and
Net worth.
Information regarding Scrapabill's relationships maintained with other FIS;
Names and locations of its customers;
Names and locations of its suppliers;
Identifying board members;
Review of the company’s website: and
Business plan.
Police Chartered Records.

Policy Statement

It is Scrapabill's policy that each Customer shall be assigned an appropriate risk rating at the inception of the Customer relationship to ensure the necessary level of monitoring/enhanced due diligence.

D. Annual Review of Risk Rating Methodology

Procedures for Review of Risk Rating Methodology

(Applicable to Compliance Officer and Compliance Committee)

The Scrapabill ’s Risk Rating Methodology shall be reviewed by the Compliance Officer at least annually.

The Compliance Officer shall consider the following factors in his review of the Scrapabill ’s Risk Rating Methodology:

impact of any regulatory changes;
the AML/CFT Risk Assessment under the AML/CFT Manual (which itself is annually reviewed and updated);
significant new products, services or lines of business individual risk factors to determine whether they adequately support the risk profile of the Scrapabill ;
the mathematical calculations (assigning points to factors and score ranges for different ratings) to determine whether they are appropriate;
generate a report of accounts and their assigned risk ratings. This can be done for all accounts or for a certain period of time (i.e. accounts opened this year). Look at the number of accounts in each risk category to judge whether it appears to be a good representation of the account population; and
review a sample of files with scores just below and above each risk rating factor (for example Low, Moderate, & High). If it appears that they would be better represented in a different category, this could be an indication that the numeric scoring needs to be adjusted.
In the event that the Compliance Committee approves changes to the Scrapabill ’s Risk Rating Methodology, the Compliance Officer shall be responsible for (a) amending the Scrapabill ’s policies, procedures, programs and systems to reflect the change in methodology; and (b) implementing the Scrapabill ’s new Risk Rating Methodology.

Policy Statement

It is Scrapabill ’s policy to annually review the Scrapabill ’s Risk Rating Methodology in order to ensure that the methodology is updated on an ongoing basis and that all relevant risk factors are incorporated.

E. Reviewing Customer File & Risk Rating / Updating Information

The Chief Compliance Officer or his designee is responsible for reviewing a Customer’s file and risk rating on a periodic basis. At this time the file can be reviewed to ensure it contains current information/documents.

During this review, the CCO or his designee should consider whether there have been any significant changes to the Customer that may warrant a change in risk rating. Significant changes would include: changes to the type of business; adding new lines of businesses; changes in geography; changes in occupation; new business owners, principals or guarantors; changes in products & services used; changes in PEP status.

Policy Statement

It is Scrapabill’s policy to review the files of customers designated as High Risk on an annual basis to ensure that the information on file is accurate, updated and complete.

It is Scrapabill’s policy to review the files of customers designated as Moderate Risk to ensure that the information on file is accurate, updated and complete upon the earlier of the generation of: (a) three (3) transaction-monitoring variances (profile exceptions) in a twelve (12)-month period; or (b) no transaction-monitoring variances (profile exceptions) in a three (3)-year period.

It is Scrapabill ’s policy to obtain and complete a new KYC/CDD profile (for Individuals or Business) upon the occurrence of an event which significantly alters the Customer’s existing profile, such as, adding Cardholders and signers or changing a significant service.

Procedures for Updating High Risk Customer Files

(Applicable to Account Representatives, Compliance Officer and Compliance Committee)

Account Representatives will update the KYC/CDD information for each Customer designated as high risk on an annual basis and obtain such documentation as required. The review will be evidenced by the updated KYC/CDD information. The Account Representatives may request information from the Customer as may be necessary to update the KYC/CDD. The review will also include a review of the applicable account documentation to ensure that such documentation is current.
Updated KYC should indicate any significant known events affecting the Customer such as change in ownership, significant business expansion or contraction, change in line of business, etc.

Procedures for Updating Moderate/Low Risk Customer Files

(Applicable to Account Representatives, Compliance Officer and Compliance Committee)

Consistent with the Scrapabill ’s established schedules, triggers and timeframes, the KYC/CDD information for accounts designated Moderate Risk and Low Risk, respectively, will be updated by the Account Representatives, as necessary.
The Account Representatives may request information from the Customer as may be necessary to update the KYC/CDD. The review will also include a review of the relevant account documentation to ensure that such documentation is current and in compliance.

Section VIII: Monitoring and Suspicious Activitiy Reporting

It is Scrapabill’s policy to implement and maintain effective internal controls and related procedures for identifying, analyzing, monitoring, and reporting suspicious transaction/activity. Any Suspicious Activity shall be reported to the Financial Transactions and Reports Analysis Centre of Canada, all transactions it deems suspicious by filing a Suspicious Activity Report (SAR).

An integral part of the Scrapabill’s AML/CFT Program includes procedures and controls for identifying “suspicious” activities and dealing with them accordingly. With the objective of establishing a systematic risk-based monitoring program to review the customers activities, Scrapabill has adopted the following system and procedures to monitor transactions and activities conducted through the use of the products. The primary purpose of the ongoing monitoring is to prevent the use of Scrapabill’s products as a conduit for illicit activity, including but not limited to, money laundering. Through the use of various reports that are generated at different intervals, the Scrapabill monitors transactions conducted through the Scrapabill to determine if patterns of unusual or illicit activity that may be suspicious are detected or to see if a client’s activity falls outside of the client’s profile. In addition, the Scrapabill has conducted a study of its clients and accounts and has classified each client and account as HIGH, MODERATE or LOW risk. In order to properly allocate its resources in the most efficient manner possible, the extent of the monitoring for each client and account is directly dependent on the risk rating assigned to such client and/or account.

Scrapabill use a Monitoring Transaction Matrix (The Monitoring Matrix) a manual tool developed by Scrapabill which allows to verify the quantity of transactions performed by a customer, its average debit, average and average balance. A relevant member of the Compliance Department verifies any unusual transaction or any pattern in the customer transactional behavior and informs to the Chief Compliance Officer.

Scrapabill considers any Anti-Money Laundering and Terrorist Financing Red Flags as:

Customers Who Provide Insufficient or Suspicious Information.
A customer uses unusual or suspicious identification documents that cannot be readily verified.
A customer provides a new individual taxpayer identification number from one jurisdiction after having previously used a different tax identification number from another jurisdiction.
A business is reluctant, when establishing a new account, to provide complete information about the nature and purpose of its business, anticipated account activity, prior Scrapabill ing relationships, the names of its officers and directors, or information on its business location.
The customer’s background differs from that which would be expected on the basis of his or her business activities.
A customer makes frequent or large transactions and has no record of past or present employment experience.
Many funds transfers are sent in large, round dollar, hundred dollar, or thousand dollar amounts.
Funds transfer activity occurs to or from a financial secrecy haven, or to or from a higher-risk geographic location without an apparent business reason or when the activity is inconsistent with the customer’s business or history.
Funds transfer activity occurs to or from a financial institution located in a higher-risk jurisdiction distant from the customer’s operations.
Many small, incoming transfers of funds are received. All or most of the transfers or deposits are wired to another city or country in a manner inconsistent with the customer’s business or history.
Large, incoming funds transfers are received on behalf of a foreign client, with little or nonexplicit reason.
Funds transfer activity is unexplained, repetitive, or shows unusual patterns.
Payments or receipts with no apparent links to legitimate contracts, goods, or services are received.
A large number of incoming or outgoing funds transfers take place through a business account, and there appears to be no logical business or other economic purpose for the transfers, particularly when this activity involves higher-risk locations.
Multiple personal and business accounts or the accounts of nonprofit organizations or charities are used to collect and funnel funds to a small number of foreign beneficiaries.
Activity Inconsistent with the Customer’s Business
Funds are generated by a business owned by persons of the same origin or by a business that involves persons of the same origin from higher-risk countries (e.g., countries designated by national authorities and FATF as noncooperative countries and territories).
The stated occupation of the customer is not commensurate with the type or level of activity.
Persons involved in currency transactions share an address or phone number, particularly when the address is also a business location or does not seem to correspond to the stated occupation (e.g., student, unemployed, or self-employed).
Unusual transfers of funds occur among related accounts or among accounts that involve the same or related principals.
Goods or services purchased by the business do not match the customer’s stated line of business.
Shell Company Activity.
Scrapabill is unable to obtain sufficient information or information is unavailable to positively identify originators or beneficiaries of accounts or other Scrapabill ing activity.
Payments to or from the company have no stated purpose, do not reference goods or services, or identify only a contract or invoice number.
Transacting businesses share the same address, provide only a registered agent’s address, or have other address inconsistencies.
Unusually large number and variety of beneficiaries are receiving funds transfers from one company.
Frequent involvement of multiple jurisdictions or beneficiaries located in higher-risk offshore financial centers.

Also, Scrapabill defines Red Flags for employees as:

Employee exhibits a lavish lifestyle that cannot be supported by his or her salary.
Employee fails to conform to recognized policies, procedures, and processes.
Employee is reluctant to take a vacation.
Employee overrides a hold placed on an account identified as suspicious so that transactions can occur in the account.
[Please refer to Code of Ethics for additional information].

Red Flags that may involve the Proceeds of Foreign Official Corruption

A request by a Covered Person to establish a relationship with, or route a transaction through, a financial institution that is unaccustomed to doing business with foreign persons and that has not sought out business of that type.
A request by a Covered Person to associate any form of secrecy with a transaction, such as booking the transaction in the name of another person or a business entity whose beneficial owner is not disclosed or readily apparent.
The routing of transactions involving a Covered Person into or through a secrecy jurisdiction or through jurisdictions or financial institutions that have inadequate customer identification practices and/or allow third parties to carry out transactions on behalf of others without identifying themselves to the institution
The use by a Covered Person of accounts at a nation's central Scrapabill or other government-owned Scrapabill , or of government accounts, as the source of funds in a transaction.
The rapid increase or decrease in the funds or asset value in an account of a Covered Person that is not attributable to fluctuations in the market value of investment instruments held in the account.
Frequent or excessive use of funds transfers or wire transfers either in or out of an account of a Covered Person.
Wire transfers to or for the benefit of a Covered Person where the beneficial owner or originator information is not provided with the wire transfer, when inclusion of such information would be expected.
Large currency or bearer instrument transactions either in or out of an account of a Covered Person.
The deposit or withdrawal from a Covered Person’s account of multiple monetary instruments just below the reporting threshold on or around the same day, particularly if the instruments are sequentially numbered.
High-value deposits or withdrawals, particularly irregular ones, not commensurate with the type of account or what is known and documented regarding the legitimate wealth or business of the Covered Person.
A pattern that after a deposit or wire transfer is received by a Covered Person’s account, the funds are shortly thereafter wired in the same amount to another financial institution, especially if the transfer is to an account at an offshore financial institution or one in a "secrecy jurisdiction."
The frequent minimal balance or zeroing out of an account of a Covered Person for purposes other than maximizing the value of the funds held in the account ( e.g., by placing the funds in an overnight investment and having the funds then return to the account).

The Compliance Officer is ultimately responsible for monitoring transaction activity passing through customer accounts, to determine if such activity is consistent with the established profiles and parameters of the customer, in order to detect unusual activity that may warrant an analysis of account activity.

Nevertheless, all employees of Scrapabill have an obligation to be on the look-out for transactions and activities occurring and/or passing through the Scrapabill that are unusual and/or suspicious and that need to be internally reported by associates to the Compliance Officer. In that regard, each Scrapabill representative is responsible for keeping abreast of the activities of every account/customer assigned to the representative.

A. SAR Filing; Reporting; Confidentiality:

Scrapabill’s policies and procedures set forth in the AML/CFT Manual regarding the filing, reporting, confidentiality and record retention of SARs are hereby incorporated by reference.

Policy Statement

It is Scrapabill’s policy to require all employees of Scrapabill to report any unusual activity that is detected, occurring in, or passing through Scrapabill to the Compliance Officer.

The determination whether a behavior, transactions or activity is suspicious, requiring the filing of a SAR, shall be the responsibility of the Compliance Officer and will not require the approval of the Board of Directors.

B. Procedures For Handling Unusual and/or Suspicious Activity

In the event that the activity/transaction being reported to the Compliance Officer involves a possible insider of Scrapabill, Scrapabill employee may write “Anonymous” instead of providing his/her name and signature. If the Compliance Officer is the subject of the Investigation the notice should be made directly to the Board or a member of the Compliance Committee of Scrapabill instead of the Compliance Officer.
The Compliance Officer shall promptly evaluate the information and determine if the transaction/activity in question warrants further review. If so, the Compliance Officer shall conduct such investigation of the activity/transaction as deemed necessary. The investigation should include, but not be limited to, discussing the activity with the relevant Scrapabill employee, reviewing the customer file (if any) and reviewing the specific transaction under consideration. The Compliance Officer may consult with legal counsel in the determination of whether such transaction or activity is suspicious and therefore reportable.
In the event that the Compliance Officer determines that a transaction or activity is suspicious and thus reportable through a SAR, the Compliance Officer shall proceed to prepare and file a SAR in accordance with the Scrapabill ’s policies and procedures set forth in this Manual.
Otherwise, in the event that the Compliance Officer determines that a transaction or activity is not suspicious and reportable through a SAR, the Compliance Officer shall note in the Investigation Log that the investigation is concluded, and no further action is required. The Compliance Officer shall also complete an investigative summary describing the investigative steps taken and the final outcome of the investigation resulting in the decision not to file a SAR

C. Procedures for Employees Engaged in Suspicious Activity

(Applicable to all Scrapabill employees)

If an employee is suspected of engaging in any type of unusual or suspicious activity, this must be brought to the attention of the Compliance Officer immediately.
The Compliance Officer will investigate the actions of the employee in a discreet manner. All actions taken to conduct the investigation must be documented.
If the Compliance Officer determines that the employee’s activity was prejudicial to the interests of Scrapabill, it will determine whether disciplinary action is necessary. The Compliance Officer will seek advice from legal counsel prior to taking such action.
If the Compliance Officer is the person engaged in unusual or suspicious activity, the employee detecting the unusual or suspicious activity must contact the Board or a member of the Compliance Committee. If a member of the Compliance Committee is contacted, such member shall advise the Board promptly of such activity involving the Compliance Officer. The Board will be responsible for conducting the investigation thereafter.
Except in those instances where the Compliance Officer is the person engaged in the unusual or suspicious activity, the Compliance Officer will have responsibility for the filing of any required SAR. If the Compliance Officer is the person engaged in the unusual or suspicious activity, the Board will have responsibility for the filing of the SAR.
The decision to file a SAR will be independent of any disciplinary action (e.g., termination, suspension, etc.) that may be taken against the employee.

D. Ongoing Transaction Monitoring

As part of Scrapabill’s procedures, all transactions must be submitted to the Compliance Department for approval. A revelvant member of the Compliance Department verifies -in real time- each transaction and compares, through the Monitoring Matrix, if the activity is concordance with the customers transactional behavior. The Compliance Officer may request additional information on the reviewed transaction.

In a monthly basis, Scrapabill analyze the historical behavior of its customers and identify transactions that might be subjetcto to suspicious activity report to relevant authorities.

E. Record Keeping

Policy Statement

It is Scrapabill ’s policy maintain the Suspicious Activity Reports (SAR) for a minimum of five (5) years after termination of the relationship with the customer.

F. Confidentiality

Scrapabill is committed to cooperate with whenever the authorities that demand it, this includes sharing the Suspicious Activity Report (SAR) and supporting documentation. The SAR’s will not be shared to external auditors and/or correspondent Scrapabill without the approval of the relevant authorities.

Section IX: Implementation of New Products and Technologies

Certain products and services offered by Scrapabill s may pose a higher risk of money laundering or terrorist financing depending on the nature of the specific product or service offered. Such products and services may facilitate a higher degree of anonymity, or involve the handling of high volumes of currency or currency equivalents.

The Compliance Officer or any designated member of the compliance department will attend the Board of Directors meeting where the implementation of a new product and/or technology is being discussed. The Compliance Officer will be responsible for conducting a Risk Assessment.

The risk assessment process will identify the new products or services, customers that will use this products, entities, and geographic locations unique to the Scrapabill . Various factors, such as the number and volume of transactions, geographic locations, and nature of the customer relationships, should be considered when the risk assessment is prepared. The differences in the way a Scrapabill interacts with the customer (face-to-face contact versus electronic Scrapabill ing) also should be considered. Because of these factors, risks vary from one product to another.

The implementation of new technologies has a direct impact in the customer risk assessment therefore It is the Scrapabill ’s policy to include the Compliance Officer or any other relevant member of the Compliance Department to the meeting where the implementation is discussed in order to design and/or adjust the Scrapabill’s risk assessment and develop written policies and procedures to mitigate the risk associated with new products and technologies.

Section X: Independing Testing of the AML/CFT Compliance Program

Scrapabill recognizes that in order to maintain an effective AML/CFT Compliance Program, it is imperative to have an independent audit in place to assist the Scrapabill to verify compliance by Scrapabill and its employees with the policies and procedures set forth in this Manual and to detect any deficiencies or failures in the AML/CFT Compliance Program.

Scrapabill’s auditing and testing of the AML/CFT Compliance Program includes audits by both internal and independent auditors. The auditors must document:

Scope
Procedures performed
Transaction testing completed
Findings of the review

The Compliance Department must fully cooperate with all auditors and compliance reviewers and with governmental regulatory examination staff by making himself/herself available to discuss all aspects of the AML/CFT Compliance Program and by providing the documents, reports, etc. that may be required by the auditing function.

Policy Statement

It is Scrapabill’s policy to ensure that a qualified independent auditor conduct the Scrapabill ’s annual Audit and independent testing of AML/CFT Program.

A. General Procedures for Auditing and Independent Testing of the AML/CFT Program

The Compliance Officer shall ensure that an independent annual Audit of Scrapabill is performed which shall include independent testing. The testing may be conducted by internal personnel of Scrapabill, so long as none of the reviewers are the designated Compliance Officer or report directly to the Compliance Officer, or by internal or external independent auditors.
The Compliance Officer shall cooperate fully by providing all information/documentation that may be required to conduct and complete the audit. The Compliance Officer shall make himself/herself available to discuss all aspects of the AML/CFT Program.
The Compliance Officer shall ensure that the independent audit is concluded with a detailed audit report (Audit Report), which shall clearly explain the scope, methodology, testing and results of the audit. As soon as the Audit Report is completed, the Compliance Officer will immediately review the Audit Report.
The Compliance Officer shall ensure that the Audit Report and his/her comments and/or responses are promptly delivered to the Compliance Committee at the next scheduled meeting.
The Compliance Officer shall ensure that all corrective actions required by the Audit Report are taken and that the exceptions are promptly resolved. The Compliance Officer shall also ensure that any necessary enhancements to the AML/CFT Program are undertaken.
The Compliance Officer shall ensure that the Audit Report (and work papers) are maintained for a period of five (5) years from the date of issuance and are readily available upon request.

Section XI: Training

Compliance with the AML/CFT Manual is a condition of employment for all Scrapabill employees. All employees are required to comply with the standards set forth in this Manual and are required to play an active role in preventing the use of the Scrapabill’s products for illicit activity. Training will be ongoing and incorporate current developments and changes to the AML/CFT Laws and Scrapabill’s AML/CFT policies, procedures and systems.

All Scrapabill personnel shall be trained in their responsibilities, including, but not limited to, the Compliance Committee, Assistant Compliance Officer, operations department staff, Account Representatives, etc. Due to the diversity of the persons trained, Scrapabill has customized the AML/CFT training program and schedule (the Training Program and Schedule) to focus on the personnel’s job duties.

Policy Statement

It is Scrapabill’s policy to provide ongoing AML/CFT training to all appropriate Scrapabill personnel on compliance with AML/CFT laws.

A. Procedures for Training

It shall be the responsibility of the Compliance Officer to ensure that all Scrapabill personnel receive general adequate AML/CFT training, and where appropriate, functional specific training.
The Compliance Officer will prepare the Scrapabill’s annual Annual Training Program. It will be the responsibility of Scrapabill ’s senior management to ensure that all Scrapabill associates receive at least annual AML/CFT training, and where appropriate, functional specific training.
The Compliance Officer shall ensure that the scope and frequency of the training is consistent and commensurate with Scrapabill’s AML/CFT risk profile and appropriate to employee responsibilities.
The AML/CFT Training Program shall cover, among others, and as appropriate:
- legal and regulatory requirements;
- changes in legal and regulatory requirements;
- the Scrapabill ’s internal policies, procedures and systems;
- trends and developments related to money laundering and terrorist financing; and
- the compliance responsibilities of the associates trained.
- In determining the scope of the training, the Compliance Officer shall consider the following factors:
  - the necessary areas or topics to cover;
  - the appropriate timing for the training;
  - the characteristics of the associate population;
  - the Customers, products, services and transaction activity of the Scrapabill ;
  - the available resources (i.e., technology) for training;
  - the professional competence of the trainers; and
  - the proper method to measure training results (i.e., testing).

The Compliance Officer shall be responsible for organizing and coordinating all AML/CFT training sessions/progress.
The methods to be used by the Compliance Officer to deliver training include, but are not limited to, conferences, seminars, webinars, facilitator-led sessions, video conferences, staff meetings, etc.
The Compliance Officer shall maintain appropriate records of all training received by personnel, all training materials as well as a record of personnel attendance at training sessions/programs.
- Scrapabill -Wide Training. The Compliance Officer shall coordinate Scrapabill -wide training sessions for all Scrapabill associates on AML/CFT issues. All personnel will receive training that includes, among others, the following topics: AML laws, regulations, norms and guidance, SAR, KYC, funds transfers, current trends, hot topics, etc.

These training sessions will be either internal or external and shall be held at least once a year. Attendance shall be mandatory. Copies of the respective sign-in sheets and training materials shall be maintained by the Compliance Officer with a copy in the human resources department.
The Compliance Officer shall ensure that a test is administered at the conclusion of each training to ensure that AML/CFT compliance issues have been fully understood.
- Existing Personnel/Function Specific Training. The Compliance Officer shall coordinate function- specific training for the personnel requiring such training (i.e. Account Representatives). This training will address AML/CFT risks applicable to the particular business function and the Scrapabill ’s policies and procedures applicable to each.
Function-specific training sessions shall be either in-house or out-sourced and shall be held at least annually. Attendance shall be mandatory. Copies of the respective sign-in sheets and training materials shall be maintained by the Compliance Officer with a copy in the human resources department.
The Compliance Officer shall test all existing associates periodically to ensure function- specific AML/CFT compliance issues have been fully understood.
- Senior Management. The Compliance Officer shall coordinate AML/CFT training for Senior Management. In addition to any training received as an existing associate, Senior Management shall also attend at least one outside AML/CFT specific seminar or conference at least annually.

B. Compliance Department Training

It shall be the responsibility of the Board of Directors to ensure that the members of the Compliance Department personnel receive general adequate AML/CFT training. The Chief Compliance Officer and any member designated by him, shall attend to international conferences on BSA/AML/OFAC in an annual basis. Any incoming training shall be presented to the Compliance Committee for its approval.

The Compliance Officer may coordinate an external training with BSA/AML/OFAC specialist or firm. The content of the training shall be presented to the Compliance Committee and, if necessary, designated members of Scrapabill’s personnel will participate in the training.

Section XII: Compliance Functions

It is Scrapabill ’s policy - as of its Board of Directors, Senior Management, employees and staff to comply with all regulations pertaining to anti-money laundering and counter financing terrorism as they apply to financial institutions. To this extent, Scrapabill has set forth its written program of internal controls which has been drafted and developed to comply with both provisions pertaining to the AML/CFT Program.

Scrapabill is aware of the risks financial institutions are exposed to, regarding money laundering. Furthermore, Scrapabill has performed its own risk assessment based on its size, the market where it operates, its customers base, and the products it offers, and has determined that it has a moderate risk regarding money laundering.

Based on the foregoing, Scrapabill is committed to comply with its AML/CFT Program, to devote the resources it deems necessary for its effectiveness, and to require from each existing and new employee, his or her commitment to compliance with it as a condition of employment, in order to mitigate the risks of money laundering.

A. Responsibilities

Several groups and persons within the Scrapabill are responsible for sharing in the task of ensuring that the Scrapabill ’s AML/CFT Program serves the needs of the Scrapabill and, therefore, have been assigned the duties and responsibilities set forth below.

Board of Directors/Advisory:

Has ultimate responsibility for Scrapabill ’s AML/CFT compliance.
Will monitor and oversee the compliance activities of Scrapabill to ensure they are in accordance with applicable laws, regulations and internal policies and procedures.
Will review the AML/CFT Compliance Program to ensure it is comprehensive, adequate, and viable
Will approve the AML/CFT Compliance Program.
Once the Directorship has approved the AML/CFT Compliance Program, must
ensure that it is effectively implemented by the Scrapabill’s Management and AML/CFT Compliance Officer
Will designate a qualified employee to serve as Scrapabill’s Compliance Officer.
Will review the performance of the Compliance Officer.
Is responsible for ensuring that the Compliance Officer has sufficient authority and resources (monetary, physical and personnel) to administer an effective AML/CFT Compliance Program based on the Scrapabill 's risk profile.
Will designate and contract the services of a competent entity to perform an independent.

AML/CFT compliance review to test the accuracy of the AML/CFT Compliance ProgramC

Compliance Department

Administer the AML/CFT Compliance Program.
Will oversee that all areas/departments of the Scrapabill adhering to the policies, procedures and controls established to comply with Scrapabill Secrecy Act and its implementing regulations, and all other AML/CFT laws and regulations.
Must be a member of Scrapabill’s AML/CFT Compliance Committee and perform all functions in such capacity.
Will support Management and staff in their efforts to ensure that the Scrapabill is in
compliance with the AML/CFT laws and regulations.
Will monitor the activities of all staff members responsible for new account relationships to ascertain that the staff is strictly following due diligence guidelines, policies and procedures.
Will monitor Scrapabill ’s compliance with OFAC regulations by ensuring that all accounts and transactions are filtered through the OFAC filter, that any matches are immediately reported, and that the lists are current at all times.
Will monitor the operational activities of the Scrapabill by reviewing reports generated by staff and by the system, inspecting documents completed and/or executed by customers, internal memoranda, etc. to determine if AML/CFT regulations are being complied with by the staff.
Will notify the AML/CFT Compliance Committee of any instances of known or suspected criminal activities, whether from internal or external sources.
Will prepare, or cause to be prepared, and file the reports required by Scrapabill regulatory authorities to comply with AML/CFT laws and regulations.
Will maintain and update, on a regular basis, the AML/CFT Compliance Program to ensure that it accurately reflects any changes in the current laws and regulations that apply to the Scrapabill.
Will update Scrapabill forms, documents and notices in order to comply with existing AML/CFT legal and regulatory requirements.
Will review all the documentation pertaining to subpoenas, summons, and other legal documents served on Scrapabill to determine if further investigation is warranted.
Will institute an on-going training and testing program for the entire staff to provide comprehensive and up to date education on the AML/CFT laws and regulations that affect the activities of the Scrapabill and the functions of the staff.
Will encourage staff members to communicate any compliance concerns or questions.
Will maintain AML/CFT related resource manuals and disseminate to appropriate staff information related to AML/CFT compliance.
Will research and respond to AML/CFT compliance-related questions from Scrapabill personnel, using the Scrapabill ’s compliance regulatory reference materials, regulatory agencies, compliance consultants, and external legal counsel, as appropriate.
Will coordinate with regulatory agency examiners during AML/CFT compliance regulatory examinations. Furnish examiners with requested information and act as primary examination contact.
Will assist the auditors and independent compliance reviewers by providing documents, reports and any other compliance information as may be required during the course of an audit or review.
Will take necessary action to coordinate and oversee the correction of violations and deficiencies noted during internal audits, compliance reviews, and/or regulatory examinations.

AML/CFT Compliance Committee

The AML/CFT Compliance Committee will consist of at least two and no more than four Board members. The Board or its nominating committee will appoint committee members and the committee chair. The Board will also appoint the “AML/CFT Compliance Officer” for Scrapabill who will serve on the committee but will report directly to the Board. The Board may also engage the services of an outside AML/CFT Compliance consultant who shall serve on the committee as a non-voting member. Members will be expected to stay abreast of AML/CFT laws and regulations affecting Scrapabill .

Scrapabill’s AML/CFT Compliance Committee should consist of the following members:

Member of the Board. The Chairman of the AML/CFT Compliance Committee will be responsible for heading the meetings. The Chairperson must ensure that all issues before the Committee are handled appropriately and on a timely basis. The Chairperson is responsible for scheduling meetings, and notification to the members will be provided by the AML/CTF Compliance Officer.
The AML/CFT Compliance Officer will prepare and present the agenda for each AML/CFT Compliance Committee meeting that includes all pending AML/CFT compliance issues affecting Scrapabill including, but not limited to, new laws, regulations and norms, amendments to existing laws, regulations and norms, suspicious transaction/activity detection and reporting and compliance deficiencies and any other problems and/or issues relating to AML/CFT.

The AML/CFT Compliance Officer will maintain the minutes/ records of the committee meetings for reference as well as a means of tracking all discussions and decisions brought before the Committee. The AML/CFT Compliance Officer is also responsible for compiling and retaining all Committee minutes, records, audit and review reports, etc. presented to the AML/CFT Compliance Committee.

The following are duties and responsibilities that the Board has delegated to the AML/CFT Compliance Committee to:

Evaluate the adequacy of the scope and testing of the AML/CFT Compliance Program and make recommendations for changes to the Board.
Monitor Scrapabill’s adherence with the AML/CFT Compliance Program established by Scrapabill .
Determine the adequacy of controls and procedures in place to ensure compliance with AML/CFT laws and regulations.
Determine that appropriate corrective action has been taken or initiated in response to matters pertaining to the AML/CFT Compliance Program.
Evaluate the adequacy of the AML/CFT Compliance training required for all employees of Scrapabill and make recommendations for changes.

Location and Frequency of Meetings: The AML/CFT Compliance Committee will meet on a monthly basis. If necessary, meetings may be re- scheduled in order to accommodate Scrapabill’s general operations and to ensure that full attendance of the committee members is obtained as often as possible.

Section XII: Know Your Employee

A. Hiring and recruiting staff

As part of the recruiting and Know Your Customer processes, the company will request the following documentation:

Identification documents
Resume
Academic and courses certificates

Scrapabill will conduct a personal, professional and financial background check of the candidate when considering their application. Senior management and managers must know the staff in their department and report any substantial change in the financial situation or in the spending habits of the employees working directly under them.

At the same time, the Compliance Department must control that the name of the applicant or employee is not listed in the OFAC, PEPs and/or “Blacklist NIB” watch lists. Every person in The Scrapabill ’s payroll will be screened against these lists daily.

B. Employee requirements

Each manager or direct supervisor, shall be responsible for providing their employees the following documents:

Code of ethics
Confidential agreement
Job offer letter

The documents must be signed by all employees and sent to the Compliance Department for its inclusion in the employees file.

C. Monitoring employee behavior

In order to ensure the integrity of Scrapabill’s staff, supervisors must monitor their staff’s behavior so as to identify and report any situations that might be considered suspicious.

The following are examples of situations to watch out for:

Sudden and significant changes in their standard of living.
Lifestyle and spending habits that aren’t consistent with their salary, financial position or level of
indebtedness.
If employee refuses to take time off for no apparent reason.
Employees who don’t allow other colleagues to assist certain customers.
If employee suspiciously receives gifts or gratuities on a regular basis.

Exhibits

Exhibit 1: Account Opening and Cash Support Request Withdrawal requirements

A. Individuals

Identification Document (Passport or government issued identification)
ID verification process
Utility Bill.
Proof of employment/ Job Letter
Resume
One (1) Scrapabill Reference or Account Statement
Account Opening Forms.
FATCA Form

Corporate
- Articles of Association / Articles of Incorporation / Company register or applicable document regarding the company’s incorporation.
- Utility Bill.
- Brochure / Business Plan.
- Account Opening Forms.
- Scrapabill Reference.
- Financial Statements.
- FATCA Form.
- Shares Certificates.
- UBO’s Identification Document.
- UBO’s Utility Bill.
- UBO´s Resume.
- If the shareholder of the Accountholder is corporation, Scrapabill will request all.