Anti-Money Laundering (AML) Policy

1. Introduction and Purpose

M.L. First Class Marketing is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines our procedures and controls to detect, prevent, and report suspicious activities in compliance with applicable laws and regulations.

2. Scope

This policy applies to all users of the SESender platform, all employees and contractors of M.L. First Class Marketing, and all transactions processed through our platform. We accept cryptocurrency payments (Bitcoin, Ethereum, USDT), which requires enhanced due diligence procedures.

3. Customer Due Diligence (CDD)

We implement the following customer due diligence measures:

3.1 Customer Identification

• Collect and verify customer identity information during registration
• Verify email addresses and, where applicable, business information
• Screen customers against sanctions lists and politically exposed persons (PEP) databases

3.2 Enhanced Due Diligence

For high-risk customers or large transactions, we may require additional documentation, including government-issued identification, proof of business registration, source of funds documentation, and beneficial ownership information.

4. Cryptocurrency Payments

Given that we accept cryptocurrency payments, we implement additional controls:

• Monitor cryptocurrency transactions for suspicious patterns
• Use blockchain analytics tools to assess transaction risk
• Require verification for transactions above certain thresholds
• Maintain records of all cryptocurrency transactions
• Refuse transactions from known high-risk wallets or mixers

5. Transaction Monitoring

We monitor transactions for suspicious activity, including:

• Unusual transaction patterns or volumes
• Transactions inconsistent with customer profile
• Attempts to structure transactions to avoid thresholds
• Use of multiple accounts or identities
• Rapid movement of funds
• Transactions involving high-risk jurisdictions

6. Record Keeping

We maintain comprehensive records of all customer identification documents, transaction records, and due diligence information for a minimum of five years after the end of the customer relationship or the date of the transaction, whichever is later. These records are stored securely and made available to regulatory authorities upon request.

7. Suspicious Activity Reporting

When we identify suspicious activity, we will file appropriate reports with relevant authorities, document our findings and actions taken, cooperate fully with law enforcement investigations, and maintain confidentiality of reports and investigations. We may suspend or terminate accounts pending investigation without prior notice.

8. Prohibited Activities

The following activities are strictly prohibited on our platform:

• Money laundering or terrorist financing
• Fraud or identity theft
• Use of stolen or unauthorized payment methods
• Transactions involving sanctioned individuals or entities
• Any activity that violates applicable laws

9. Training and Awareness

All employees involved in customer onboarding, transaction processing, or compliance receive regular training on AML procedures, red flags for suspicious activity, and reporting requirements. Training is updated annually and whenever significant regulatory changes occur.

10. Compliance Officer

We have designated a Compliance Officer responsible for implementing and maintaining our AML program, ensuring compliance with applicable laws, reviewing and updating policies and procedures, and serving as the point of contact for regulatory inquiries.

11. Policy Review

This AML Policy is reviewed and updated annually, or more frequently if required by changes in law, regulation, or business practices. Updates are communicated to all relevant personnel.