Policy Scope

This AML & CTF Policy applies to all employees, officers, partners, and representatives of AYBANK INC. It defines our framework, processes, and systems designed to prevent illegal financial activity. The Chief Compliance Officer ensures the policy is current and all team members are aware of their obligations.

What Is Money Laundering?

Money laundering disguises the origin of funds derived from illegal activity to make them appear legitimate. It includes three stages: (1) Placement – introducing illicit funds into the system, (2) Layering – concealing their origin via complex transactions, and (3) Integration – reintroducing them as legitimate assets.

What Is Terrorism Financing?

Terrorism financing involves collecting or providing funds intended to support terrorist acts or organizations. AYBANK monitors and reports suspicious activity to the Financial Services Unit (FSU) of Dominica.

Proliferation Financing

AYBANK prohibits the use of its systems to fund or facilitate the development, acquisition, or transport of nuclear, chemical, or biological weapons or related materials.

Risk-Based Approach

AYBANK uses a risk-based approach, assessing risks across customer profiles, services, jurisdictions, delivery channels, and transactions. Higher-risk scenarios receive enhanced due diligence and monitoring.

Customer Due Diligence (CDD)

AYBANK verifies all customers before account opening or providing services. Verification includes identity, address, source of funds, and purpose. Enhanced Due Diligence (EDD) applies to politically exposed persons (PEPs) and high-risk clients.

Ongoing Monitoring

We continuously monitor transactions to identify unusual or suspicious activity. Suspicious activities are escalated to the AML & CTF Compliance Officer and reported to the FSU when necessary.

Employee Awareness & Training

All employees receive AML & CTF training upon hiring and regularly thereafter. Training covers AML laws, red flags, reporting obligations, and consequences of non-compliance.

Record Keeping

AYBANK maintains comprehensive AML records, including customer data, transaction history, reports, and audits for at least six years, in line with Dominica law.

Suspicious Transaction Reporting

If any activity is suspected to relate to money laundering or terrorism financing, AYBANK files a Suspicious Matter Report (SMR) with the FSU while maintaining confidentiality.

Compliance Oversight

The Chief Compliance Officer and AML Compliance Officer oversee ongoing compliance, audits, and independent reviews annually or upon regulatory changes.

Confidentiality & Data Protection

AYBANK safeguards all customer data and AML-related reports, disclosing information only to authorized bodies as permitted by law.

Cooperation with Regulators

AYBANK cooperates fully with the Financial Services Unit (FSU), the Central Bank, and law enforcement authorities to maintain transparency and compliance.

Legal Framework

This policy is governed by the Anti-Money Laundering and Counter-Terrorism Financing Act, the Money Laundering Prevention Act (MLPA), and FATF/CFATF recommendations.

Contact Compliance Office

AYBANK INC – Compliance Department

2nd Floor, 38 King George V Street, Roseau, Commonwealth of Dominica

Email: compliance@aybank.com

Commitment Statement

AYBANK remains dedicated to being a trusted and transparent financial institution, ensuring our systems are never used for illegal or unethical purposes.