WODI Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy 🛡️

1. WODI's Policy Statement

It is the policy of WODI (referred to as "the firm") to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. This is achieved by complying with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

2. AML Compliance Person Designation and Duties 🧑‍💼

Ousmane Conde has been designated as WODI's Anti-Money Laundering Program Compliance Person (AML Compliance Person), holding full responsibility for the firm’s AML program. The duties of the AML Compliance Person include monitoring the firm’s compliance with AML obligations, overseeing communication and training for employees, and ensuring that Suspicious Activity Reports (SARs) are filed with the Financial Crimes Enforcement Network (FinCEN) when appropriate.

3. Customer Identification Program (CIP) ✅

Required Customer Information

Prior to opening an account, we will collect the following minimum information:

• Full Name
• Date of birth (for individuals)
• A valid physical address (residential or business)
• An identification number (e.g., TIN for U.S. persons, or passport number for non-U.S. persons).

Verifying Information

We use risk-based procedures to verify the identity of our customers. This includes documentary methods (like a driver's license or passport) and non-documentary methods (like comparing information with public databases).

Wireless Carrier Verification for Fraud Prevention

As an additional non-documentary verification and fraud prevention measure, all customers must provide authorization upon registration. This authorization permits WODI or its designated service providers to query the customer's wireless carrier. Information about the customer's account and their wireless device, if available, may be used or disclosed for the duration of the business relationship. The sole purpose of this process is to aid in verifying the customer's identity, authenticating their wireless device, and preventing fraudulent activity on the platform.

4. Advanced Security Platform: AML & KYC Verifications 🔒

WODI leverages an advanced, multi-layered system for security, KYC, and AML verification. Key features include:

• Global Sanctions and Watchlists: Users are rigorously screened against over 1,000 international sanctions and watchlists, including OFAC and Interpol, with lists updated every 15 minutes.
• Politically Exposed Persons (PEPs): Individuals in prominent public positions, along with their Relatives and Close Associates (RCAs), are screened to prevent corruption.
• Adverse Media Analysis: We scan over 10,000 global data sources to uncover links to financial crimes or unethical activities.
• Biometric Verification: In partnership with Microsoft, we verify user identity by comparing a government-issued ID scan with a live selfie.

5. Monitoring and Reporting Suspicious Activity 🕵️‍♀️

We monitor account activity for unusual patterns, volumes, or transactions that are inconsistent with a customer's risk profile. WODI will file a Suspicious Activity Report (SAR) for any transaction involving $5,000 or more that we suspect may be related to illegal activity, is designed to evade BSA regulations, or has no apparent lawful purpose.

Red Flags

Our systems and staff are trained to identify red flags, including:

• Attempts to provide suspicious or unverifiable identification documents.
• Efforts to "structure" transactions to fall below reporting thresholds.
• Unusual transfers of funds to or from high-risk geographic locations without a clear business reason.
• Sudden changes in transaction patterns that are inconsistent with the customer's known activities.

6. Training Programs 🎓

All WODI employees receive ongoing, annual training on AML and KYC policies. This training covers how to identify red flags, procedures for escalating suspicious activity, and the legal consequences of non-compliance with the BSA.