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AML Compliance Program

1. Firm Policy

It is the policy of Rapidproxy to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the financing of terrorist or criminal activities. We comply with all applicable requirements under the Bank Secrecy Act (BSA) and its implementing regulations.

Rapidproxy's AML policies, procedures, and internal controls are designed to ensure compliance with all applicable BSA regulations and relevant financial industry rules. These policies will be reviewed and updated regularly to ensure that appropriate measures are in place to account for both regulatory changes and business adjustments.

2. Giving AML Information to Federal Law Enforcement Agencies and Other Financial Institutions

We will not disclose the fact that FinCEN has requested or obtained information from us, except to the extent necessary to comply with the information request.

National Security Letters

We recognize that the receipt of a National Security Letter (NSL) is highly confidential. No manager, employee, or proxy of Rapidproxy may directly or indirectly disclose to any person that the FBI or other federal authority has sought or obtained access to our records. To maintain the confidentiality of any NSL we receive, we will process and store the NSL securely. If we file a Suspicious Activity Report (SAR) after receiving an NSL, the SAR will not reference the NSL's receipt or existence. The SAR will only contain detailed information about the detected suspicious activity.

3. Monitoring Accounts for Suspicious Activity

We monitor account activity for unusual size, volume, pattern, or type of transactions, taking into account risk factors and red flags that are relevant to our business.

Red Flags

Red flags that may signal potential money laundering or terrorist financing include, but are not limited to:

Potential Red Flags in Customer Due Diligence and Interactions with Customers

  • The customer provides unusual or suspicious identification documents that cannot be easily verified or are inconsistent with other customer-provided documents.
  • The customer is reluctant or refuses to provide the firm with complete customer due diligence information, such as the nature and purpose of their business or information on anticipated account activity.
  • The customer is unwilling to identify a legitimate source of funds, or provides false or misleading information.
  • The customer is located in, conducting business with, or frequently transacting with counterparties in jurisdictions that are known for banking secrecy, tax shelters, or ineffective AML systems, or areas with high terrorism risks.
  • The customer is unsure or vague about their business, or lacks knowledge of their industry.
  • The customer has no clear reason for using the firm’s services or location, or is making unusual efforts to use the firm.
  • The customer has been rejected by or had relationships terminated by other financial institutions.
  • The customer’s address is linked to multiple unrelated accounts or businesses.
  • The customer may be acting as a proxy for an undisclosed principal but is unwilling to provide further information.

Other Potential Red Flags

  • The customer is reluctant to provide information required to file reports for transactions.
  • The customer is unusually concerned about the firm’s compliance with government reporting requirements.
  • The customer attempts to persuade employees not to file necessary reports or to avoid maintaining required records.
  • Notifications from our clearing firm about suspicious activity detected in customer accounts.
  • The customer engages in high-value transactions that are inconsistent with their known income or financial resources.
  • The customer wishes to engage in transactions that lack business sense or an apparent investment strategy, or are inconsistent with their stated business purpose.
  • Securities transactions are unwound before maturity without logical justification.
  • The customer does not exhibit concern about transaction costs or fees.
  • The customer defaults on a cash-secured loan or any loan secured by assets readily convertible to currency.

4.AML Recordkeeping

Responsibility for Required AML Records and SAR Filing

Our designated AML Compliance Officer is responsible for ensuring that AML records are maintained accurately and that SARs are filed as required.

5. Clearing/Introducing Firm Relationships

We work closely with our clearing firm to detect and prevent money laundering. We exchange information, records, data, and exception reports necessary to comply with AML laws. We will obtain and use exception reports offered by our clearing firm to monitor customer activity and provide them with proper customer identification and due diligence information.

6. Senior Manager Approval

Senior management has approved this AML compliance program in writing, affirming that it is reasonably designed to ensure and monitor our ongoing compliance with the BSA and its implementing regulations.

Effective Date: March 1st 2025

Company: RAPID TERMINAL UK NETWORK LIMITED