Anti-Money Laundering Policy

PURPOSE

This Anti-Money Laundering (AML) Policy ("Policy") outlines the commitment of BulkSMS ("the Company") to prevent and detect money laundering and terrorist financing activities. The purpose of this Policy is to ensure compliance with applicable laws and regulations and to safeguard the integrity of the financial system.

SCOPE

This Policy applies to all employees, contractors, agents, and representatives acting on behalf of the Company ("Covered Parties"). It encompasses all business activities, both domestically and internationally.

LEGAL COMPLIANCE

The Company is committed to complying with all relevant anti-money laundering laws and regulations in which the Company and its clients operate, including but not limited to, in the case of the following countries:
1. United Kingdom: the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) and the Terrorism Act 2000 and the Proceeds of Crime Act 2002 (POCA) (as amended by the Serious Organised Crime and Police Act 2005 (SOCPA));
2. South Africa: the Financial Intelligence Centre Act 38 of 2001 and the Prevention of Organized Crime Act 121 of 1998;
3. United States: the Bank Secrecy Act (BSA), the USA PATRIOT Act; and other applicable international laws.

RISK ASSESSMENT

The Company will conduct periodic risk assessments to identify and evaluate the risks of money laundering and terrorist financing associated with its products, services, customers, and geographic locations. Appropriate measures will be implemented to mitigate identified risks.

CUSTOMER DUE DILIGENCE

The Company will establish and maintain risk-based procedures for conducting customer due diligence, including verifying the identity of customers, understanding the nature of their business, and monitoring transactions for unusual or suspicious activities.

REPORTING SUSPICIOUS ACTIVITIES

Covered Parties must promptly report any suspicions of money laundering or terrorist financing to the designated compliance officer or through the established reporting channels. The Company encourages reporting without fear of retaliation.

RECORD KEEPING

The Company will securely maintain accurate and up-to-date records of customer information, transactions, and the results of customer due diligence efforts in accordance with applicable laws and regulations.

TRAINING AND AWARENESS

The Company is committed to providing regular training to Covered Parties on anti-money laundering policies, procedures, and the importance of vigilance in detecting and preventing money laundering and terrorist financing activities.

MONITORING AND REPORTING

The Company will implement monitoring mechanisms to detect and report suspicious activities. Reports will be filed with relevant authorities as required by law. The Company will cooperate fully with law enforcement and regulatory agencies.

THIRD-PARTY RELATIONSHIPS

The Company will conduct due diligence on third parties, such as vendors, partners, and agents, to ensure they adhere to anti-money laundering standards. Engaging in business relationships with parties involved in money laundering is strictly prohibited.

CONSEQUENCES OF VIOLATIONS

Violations of this AML Policy will result in disciplinary action, which may include termination of employment, legal action, and potential civil or criminal penalties. The severity of the consequences will depend on the nature and extent of the violation.

REVIEW AND UPDATE

This Policy will be periodically reviewed to ensure its effectiveness and relevance. Amendments may be made to reflect changes in applicable laws or business practices.

RESPONSIBILITIES FOR THE PROCESS

The responsibilities for the preparation, verification, issue, filing and up-dating of this policy and associated processes is the duty of the Director: Operations or duly appointed representative. The monitoring, measuring and continual improvement of the procedure or process is the responsibility of the Compliance Officer or duly appointed representative.