NetLeaders AML Policy

Bank Secrecy Act and Anti-Money Laundering Compliance Program

When our system is fully deployed, CL Singapore Pte. Ltd. shall put in place a fully functional Bank Secrecy Act and Anti-Money Laundering Compliance Program (“BSA/AML Program”) based on the model below to maintain the highest possible compliance with applicable laws and regulations relating to anti-money laundering in Singapore, the United States and other countries where we will eventually conduct our business. Our system will have:
  • All requisite internal policies, procedures and controls to identify any attempts to use NetLeaders for illegal or illicit purposes and to ensure our Advocates and customers basic protections under consumer protection laws;
  • Procedures to comply with applicable regulations and guidance set forth by the Financial Crimes Enforcement Network (“FinCEN”), Suspicious Activity Reports (“SARs”), Currency Transaction Reports (“CTRs”);
  • A comprehensive records of orders and other transfers;
  • A Chief Compliance Officer who will be responsible for the implementation and oversight of our BSA/AML Program;
  • Procedures for know your customer (“KYC”);
  • Performing regular, independent audits of our BSA/AML Program; and
  • A formal and ongoing compliance training program for all new and existing employees.

Policies and Procedures

NetLeaders is regulated under by the laws of Singapore. We plan to have our BSA/AML Program reviewed and approved by the relevant authorities, and if necessary, revised in an effort to comply with applicable rules, regulations and policies.

Internal Controls

When fully implemented, our internal policies, procedures, and controls will serve to comply with applicable BSA/AML laws and regulations, some of which are outlined here on this page including, but not limited to, our Customer Identification Program (“CIP”), SARs, reporting requirements and audits.

Training

All employees and officers of NetLeaders will receive ongoing broad-based BSA/AML training as well as position-specific training. They must repeat this training at least once every twelve (12) months to ensure they are knowledgeable and in compliance with all pertinent laws and regulations. New employees will receive training within thirty (30) days of their start date. All documentation related to compliance training including materials, tests, results, attendance and date will be maintained. In addition, our compliance training program will be updated as necessary to reflect current laws and regulations.

Compliance Officer

Our Chief Compliance Officer (“CCO”) will be responsible for leading the development and enforcement of compliance policies and procedures for our BSA/AML Program. Our CCO will also be responsible for reporting any violations of our BSA/AML Program. In addition, the CCO will be responsible for recording and filing SARs, CTRs and performing a BSA/AML Program audit at least once every twelve (12) months.

Customer Identification

Our Customer Identity Program (“CIP”) will be an important part of our BSA/AML Program by helping to detect suspicious activity in a timely manner, and prevent fraud.

License Purchase Process

In order to purchase a License and use NetLeaders software system, your identity will be checked against government watch lists, including the Office of Foreign Assets Control (“OFAC”).

Individual

Prior to approving a License for an individual customer, we or our affiliated agent(s) will collect the following information:
  • Email address;
  • Mobile phone number;
Prior to approving a License for an individual customer, we or our affiliated agent(s) will collect and verify the following information:
  • Full legal name;
  • Home address (not a mailing address or P.O. Box).
Prior to transferring or withdrawing compensation earned in our marketing program on behalf of an Advocate, we or our affiliated agent(s) will collect the following information:
  • Social Security Number (“SSN”) or any comparable identification issued by government;
Prior to transferring or withdrawing compensation above a certain threshold on behalf of an Advocate (to be published in this document once the system is fully deployed), we or our affiliated agent(s) will collect, verify and authenticate:
  • Proof of identity (e.g., driver’s license, passport or government-issued ID);
  • Proof of address (e.g., electric, gas or water bill); and

If you successfully meet and complete our CIP requirements and do not appear on the OFAC or any other government watchlist, then we shall approve your License electronically and make the requested transfer.

Institution

Prior to opening an account for an institutional customer, we will collect the following information:
  • Institution legal name;
  • Address (principal place of business and/or other physical location);
  • Business phone number;
Prior to transferring or withdrawing compensation for an institutional customer acting as an Advocate, we or our affiliated agent(s) will collect the following information:
  • Employer Identification Number (“EIN”) or any comparable identification issued by government;
  • Full legal name (of all account signatories);
  • Email address (of all account signatories);
  • Mobile phone number (of all account signatories);
Prior to transferring or withdrawing compensation above a certain threshold (to be published in this document once the system is fully deployed), we or our affiliated agent(s) will collect, verify and authenticate:
  • Proof of legal existence (e.g., state certified articles of incorporation/certificate of formation, unexpired government-issued business license, trust instrument or other comparable legal documents as applicable);
  • Contract information of owners/principals/executive management (as applicable);
  • Proof of identity (e.g., driver’s license, passport or government-issued ID) for each individual beneficial owner that owns 10% or more as well as all account signatories; and
  • Identifying information for each entity beneficial owner that owns 10% or more.

If your institution successfully meets and completes our CIP requirements and its name as well as the names of its owners/principals/executive managers do not appear on OFAC or other governmental watch lists, we shall approve your License electronically.

Suspicious Activity / Currency Transaction Reports

We will file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on the NetLeaders platform. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. The Chief Compliance Officer will review and investigate suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR. In addition, all currency transactions over a determined USD value will be reported to (FinCEN) by filing of a CTR. The CCO will maintain records and supporting documentation of all SARs and CTRs filed.

Reporting Requirements

All records will be retained for seven (7) years and will be readily available upon request by the applicable examiner.

BSA/AML Program Audit

The CCO will be responsible for performing an audit of our BSA/AML Program at least once every twelve (12) months and presenting the results to the CEO and Board. The CEO will oversee the performance of an independent third-party audit of our BSA/AML Program at least once every twelve (12) months. The CCO will not be responsible for the independent audit, and the CCO’s performance will be a subject of the review. Results will be reviewed and discussed by senior management and our Board.