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AML Statement
Money Laundering is the act of disguising the source or ownership of illegally obtained money through a series of transfers designed to make it appear that the funds originated from a legitimate source.

Sincats.com takes reasonable and appropriate steps to prevent persons engaged in money laundering, fraud or other financial crime from utilizing Sincats.com's products and services to facilitate criminal activity. We have implemented an enterprise-wide Bank Secrecy Act/Anti-Money Laundering (BSA/AML) compliance program, which is applicable to all employees, contractors and affiliates. The program provides guidance through Board-approved corporate policies, written procedures and established controls designed to identify and appropriately mitigate money laundering risks. The program includes, but is not limited to, customer due diligence and account documentation requirements, identification of higher risk customers through enhanced due diligence questions, reporting of large currency transactions and monitoring customer transactions for suspicious activity.

The Board's expectations for adherence to all BSA/AML laws, rules and regulations is clearly communicated to all employees. Annual training is mandatory and participation tracked at all levels, including management and the Board. The Chief Compliance Officer apprises the Risk Committee of BSA/AML matters on a quarterly basis.

Sincats.com's BSA/AML risk level and program effectiveness is evaluated through an annual risk assessment, periodic independent third party audit and annual regulatory examinations.

Statement updated: Jan. 12, 2021