January 31th, 2023, Version 3
Espresso Cash is an online service operated by Espresso Cash Inc., an American company registered in the New Jersey under the number 0450913896.
Espresso Cash Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “AML/KYC Policy”) is designated to prevent and mitigate possible risks of Espresso Cash being involved in any kind of illegal activity. Both international and local regulations require Espresso Cash to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users. AML/KYC Policy covers the following matters: Compliance Officer, Monitoring transactions, Risk assessment.
The Compliance Officer is the person, duly authorized by Espresso Cash, whose duty is to ensure the effective implementation and enforcement of the AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Espresso Cash’s anti-money laundering and counter-terrorist financing, including but not limited to: Collecting Users’ identification information; Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations; Monitoring transactions and investigating any significant deviations from normal activity; Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs; Updating risk assessment regularly; Providing law enforcement with information as required under the applicable laws and regulations. The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
The Users are known by analyzing their transactional patterns (what they do). Therefore, Espresso Cash relies on data analysis as a risk-assessment and suspicion detection tool. Espresso Cash performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include: Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable; Case and document management. With regard to the AML/KYC Policy, Espresso Cash will monitor all transactions and it reserves the right to: Ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer; Request the User to provide any additional information and documents in case of suspicious transactions; suspend or terminate User’s Account when Espresso Cash has reasonably suspicion that such User engaged in illegal activity. The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
Espresso Cash, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Espresso Cash is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.