Anti Money Laundering Policy

Message from the President & CEO

On October 26, 2001, President Bush enacted the USA Patriot Act, aimed at preventing terrorism. Title III, known as the International Money Laundering Abatement and Antiterrorist Financing Act of 2001, specifically addresses money laundering by expanding previous laws like the Bank Secrecy Act, which mandated financial institutions to report certain transactions and criminalized money laundering.

Title III extends anti-money laundering regulations to all financial institutions, including escrow agents. The United States Treasury Department now oversees regulatory compliance and is responsible for developing and implementing regulations.

Section 352 of the Act requires all financial institutions, including escrow agents, to develop anti-money laundering policies and programs. These include:

• Establishing an independent audit function to test programs.
• Developing internal policies, procedures, and controls.
• Designating a compliance officer.
• Maintaining an ongoing training program.

To comply with the USA Patriot Act, TravelMint Inc. has developed an Anti-Money Laundering Policy that must be strictly enforced. The United States Treasury Department may enact additional regulations requiring further policies and programs.

David Ciccarelli
President and CEO

TravelMint Inc.’s Anti-Money Laundering Policy

Federal anti-money laundering legislation has prompted TravelMint Inc. to revise our policies for handling funds. These changes ensure compliance with money laundering regulations and protect TravelMint Inc. and its partners from potential criminal fines and penalties.

Definition of Money Laundering

Money laundering involves transactions designed to conceal or disguise the nature and source of funds obtained from illegal activities. The goal is to convert dirty money into clean money while leaving minimal traces of the transformation. Illegal activities commonly associated with money laundering include:

• Drug trafficking
• Terrorism
• Smuggling
• Fraud
• Bribery
• Robbery
• Embezzlement
• Illegal gambling

Stages of Money Laundering

1. Placement – Depositing illicit funds into financial institutions, converting them into financial instruments, or purchasing assets for resale. Smurfing is a common tactic, involving multiple small deposits to evade detection.
2. Layering – Separating the proceeds of crime from their origin through multiple financial transactions, making the audit trail harder to follow.
3. Integration – Reintroducing laundered funds into the economy as seemingly legitimate assets. It is illegal to transport, transmit, or transfer monetary instruments exceeding $10,000 for illicit activities or to avoid reporting requirements. Violations may result in up to 20 years in prison and fines up to $500,000.

Implementation Measures

Knowing the Source of Client Funds

Agents and employees must always be aware of the source of client funds used for transactions. Funds obtained from illegal activities must never be accepted.

Cash and Other Monetary Instruments

• Cash should never be accepted.
• Monetary instruments (cashier’s checks, money orders, bank drafts, traveler’s checks) should not be accepted or transported unless legally verified.

Acceptable Forms of Payment

• Personal or business checks drawn on a U.S. bank or a U.S. branch of a foreign bank, subject to the Bank Secrecy Act.
• Third-party checks with a clear connection to the underlying transaction.
• Cashier’s checks, money orders, bank drafts, and traveler’s checks exceeding $10,000 in a single denomination.
• Wires processed through U.S. banks, subject to the Bank Secrecy Act.

Unacceptable Forms of Payment

• Cash payments.
• Personal or business checks drawn on foreign banks.
• Third-party checks without a clear connection to the transaction.
• Checks made payable to individuals, agencies, or “cash”.
• Routine payments by cashier’s checks, money orders, bank drafts, and traveler’s checks under $10,000.
• Agents’ personal checks or agency bank account checks for client transactions.

Compliance & Training

Compliance Officer

The Chief Executive Officer (currently David Ciccarelli) serves as the Compliance Officer for this policy. Responsibilities include ensuring policy compliance, training employees, and implementing procedures aligned with current laws and regulations.

Training & Policy Awareness

• All employees, agents, and partners will receive a copy of this policy.
• New employees, agents, and partners will be provided this policy upon hiring.
• Managers are responsible for ongoing training regarding policy adherence and compliance procedures.

Audits & Compliance Monitoring

• An internal audit will be conducted within six months of the policy’s implementation.
• Audits will be conducted at regular intervals to ensure continued compliance.

Conclusion

TravelMint Inc. is dedicated to maintaining strict anti-money laundering policies to comply with federal laws, safeguard our operations, and uphold ethical business practices.

This policy was approved by Senior Management on February 28, 2025.

For questions regarding this policy, please contact legal@travelmint.com.