Amigo Travel Club KYC and AML Policies

Know Your Customer (KYC) and Anti-Money Laundering (AML) Policies

Know Your Customer (KYC) is the due diligence and bank regulation that the Amigo Travel Club, financial institutions and other regulated companies must perform to identify their clients and ascertain relevant information pertinent to doing financial business with them. In Canada, the Amigo Travel Club must be in full compliance with Canada’s Proceeds of Crime (Money Laundering) and Terrorist Financing Regulations (PCMLTFA -- governed by FINTRAC). In the USA, KYC is typically a policy implemented to conform to a customer identification program mandated under the Bank Secrecy Act and USA PATRIOT Act. Know your customer policies have becoming increasingly important globally to prevent identity theft fraud, money laundering and terrorist financing. In a simple form these rules may equate to answering twelve questions, but this is the tip of the iceberg and regulators now expect much more. KYC should not be thought of as a form to be filled - it is a process to be undergone from the start of a customer relationship to the end.

One aspect of KYC checking is to verify that the customer is not on any list of known fraudsters, terrorists or money launderers, such as the Office of Foreign Assets Control's Specially Designated Nationals list (OFAC). This list contains thousands of entries and is updated at least monthly. As well as sanctions lists there are lists of third party vendors that track links between persons regarded as high-risk owing to negative reports in the media about them or in public records.

Beyond name matching, a key aspect of KYC controls is to monitor transactions of a customer against their recorded profile, history on the customers account(s) and with peers.

Collection of Information is Required by Law to Verify Customers

1. All transactions processed by the Amigo Travel Club are subject to the regulations governing the jurisdiction in which the transaction is processed, such as the Financial Transactions Reports Analysis Centre of Canada (FINTRAC), the regulations supervised by the United Kingdom Financial Services Authority (FSA) and the Financial Crime Enforcement Network (FINCEN) of the United States Department of the Treasury. The Amigo Travel Club must adhere to the defined KYC requirements of these regulations.

2. When a Customer uses the Amigo Travel Club’s services via their online bank, the Club relies upon the bank to validate the Customer via passwords, PINs and dynamic tokens as the Customer interacts with the bank’s online service.

3. It is the Amigo Travel Club’s responsibility to verify the identity of the Customer prior to using the Club’s services so that the following standards are met. The Amigo Travel Club should obtain the following information in relation to the Customer:

• Full Name
• Residential Address
• Citizenship

4. Verification of the information obtained should be conducted EITHER electronically by the Amigo Travel Club OR based on documentary evidence provided by the customer, OR by a combination of both electronic and documentary methods.

5. If identity is submitted electronically, this will be verified by Amigo Travel Club Member Services, using as its basis the customer’s full name, address and date of birth, carrying out electronic checks either using our own in-house information, or through a supplier that provides a reasonable assurance that the customer has provided their true identity.

The standard level of ID verification is:

• One match on an individual’s full name and current address; and
• A second match on an individual’s full name and either their current address or their date of birth.
Acceptable documents for ID verification that you may scan and submit to us are as follows:
• Valid Passport;
• Valid Photo Card Driving License;
• National Identity Card;
• Identity Card issued by the Electoral Office
• Valid (old style) Drivers License (no photograph);
• Recent evidence of entitlement to a state or local authority funded benefit (including housing benefit and council tax benefit), tax credit, pension and educational or other grant;
• Instrument of a court appointment (such as liquidator or grant of probate);
• Current council tax demand letter or statement;
• Current bank statements or credit/debit card statements issued by a regulated financial sector firm or comparable jurisdiction (but excluding any statement printed from the internet); and/or
• Utility bills.
Please ensure that all four edges of the documents are visible when you upload your scanned documents into the system. The following file types can only be sent: jpg, jpeg, gif, bmp or png. Please ensure that these documents are clear and the name of your file does not contain special characters, spaces or non-English characters. The Amigo Travel Club does not except faxed copies of photo identification for verification purposes.

6. If identity is to be verified manually by an Amigo Travel Club Agent, the identification should be based on either a Government issued document that incorporates the Customer’s full name and photograph and either their residential address or their date of birth; OR a government-issued document (without a photograph) which incorporates the Customer’s full name, supported by a second document, either government issued, or issued by a judicial authority or a public sector body or authority, which incorporates the Customer’s full name and either their residential address or date of birth. Acceptable documents for ID verification are as follows:

• Valid Passport;
• Valid Photo Card Driving License;
• National Identity Card;
• Identity Card issued by the Electoral Office
• Valid (old style) Drivers License (no photograph);
• Recent evidence of entitlement to a state or local authority funded benefit (including housing benefit and council tax benefit), tax credit, pension and educational or other grant;
• Instrument of a court appointment (such as liquidator or grant of probate);
• Current council tax demand letter or statement;
• Current bank statements or credit/debit card statements issued by a regulated financial sector firm or comparable jurisdiction (but excluding any statement printed from the internet); and/or
• Utility bills.

7. Some Customers may not be able to produce identification information that will meet the required standard. Where an applicant produces non-standard documentation, a considered judgment should be made to determine if the evidence provides a sufficient level of confidence that the customer has provided adequate accurate information that authenticates their true identity.

8. When Amigo Travel Club Member Services has concluded that it should treat a Customer as financially excluded for the purposes of Customer identification, it should keep a record of the reasons for doing so. All records shall be maintained by the Amigo Travel Club for at least five (5) years from the end of the business relationship with the Customer.

Anti-Money Laundering (AML) Prevention
The Amigo Travel Club will conduct its business in conformity with the highest ethical standards in the countries in which it does business, and will adhere to all laws and regulations pertaining to financial organizations. It is vital for all Amigo Travel Club customers, agents and employees and associates to fully understand those actions that may be violations of applicable AML or counter-terrorism statutes, and to report any potential violation in the manner set forth in the appropriate AML compliance procedures.

The Amigo Travel Club will:

• Take reasonable steps to determine the true identity of all customers and beneficial ownership of accounts with the Amigo Travel Club.

• Take appropriate measures, consistent with the law, when the Club becomes aware of facts which lead to a reasonable suspicion that funds held by it are from money laundering or other criminal activity, that transactions entered into are themselves criminal in purpose, that funds are owned by a government-designated terrorist entity (such as FINTRAC in Canada and the Office of Foreign Assets Control in the US OFAC), or that transactions are intended to conduct or further terrorist activities. The appropriate measures to be taken may include: severing relations with the customer, closing or freezing accounts and filing a suspicious activity report.

• Cooperate with law enforcement and regulatory agencies to the extent that it can do so under all applicable foreign and domestic laws.

• Comply with all AML and counter-terrorism laws and regulations, including reporting and blocking of assets, to the fullest extent that it can do so under all applicable foreign and domestic laws.

While preventing the misuse of the Amigo Travel Club by terrorists and other criminals is of vital importance, associates must not draw conclusions about customers and their banking activities based solely on the customers' religious affiliation, ethnicity, or national origin.
Every Amigo Travel Club employee is responsible for complying with all applicable AML laws, regulations, the Policy and procedures that implement the Policy. Complete details are in the Amigo Travel Club AML Policy.

Subsection (1) of 18 U.S.C. §1956 makes it illegal to conduct or attempt to conduct a financial transaction with proceeds known to be from specified unlawful activity with:

(1) intent to promote the carrying on of specified unlawful activity:

(2) intent to evade taxes; or

(3) knowledge that the transaction is designed to conceal or disguise the nature of the proceeds or to avoid a state or federal transaction reporting requirement.

The law requires us to monitor any unusual or suspicious transactions of any size taking place where we have reasons to believe the money is derived from illegal activity. The law also requires us to keep full records of all transactions of U.S. $10,000 and above, together with copies of all identifying data. Identification may be in the form of a passport, driver's license, credit / debit card, or bank account. We are unable to process any transaction where this information is withheld. We have a legal obligation to report to The Canadian Government and the U.S. Treasury Dept. any such suspicious transactions. The definition of a suspicious transaction is one that raises "an unconfirmed belief" or any type of suspicion of such activities.