Zil Money is a financial technology company, not a bank or an FDIC member. Zil Money offers banking services through partnership with FDIC member banks Silicon Valley Bank, Texas National Bank, and East-West Bank.

OFAC SCREENING AND REPORTING MANUAL

INTRODUCTION:

At Zil Money, we are committed to maintaining the highest standards of compliance with regulatory requirements and industry best practices. This OFAC Screening and Reporting Manual serves as a comprehensive guide to our approach in ensuring adherence to the regulations set forth by the Office of Foreign Assets Control (OFAC). With a focus on transparency, accuracy, and efficiency, this manual outlines the policies, procedures, and strategies we have implemented to prevent transactions with individuals or entities listed on the OFAC sanctions list.

(a) Purpose of the Manual:

The purpose of this manual is to provide a concise and detailed overview of our OFAC screening and reporting processes. It serves as a reference document for all employees and stakeholders involved in the compliance efforts, demonstrating our dedication to upholding financial integrity and safeguarding against financial crimes such as money laundering and terrorist financing.

(b) Scope and Applicability:

This manual is applicable to all activities conducted within Zil Money, including but not limited to our banking partners, third-party service providers, and customers. It encompasses the screening of users, vendors, and transactions to ensure full compliance with OFAC regulations. This document shall be adhered to by all personnel, and any changes or updates will be communicated promptly to maintain uniformity in our compliance measures.

The Office of Foreign Assets Control (OFAC) is a vital regulatory body responsible for enforcing economic and trade sanctions based on the foreign policy objectives of the United States. Compliance with OFAC regulations is crucial for financial institutions and fintech companies like ours to prevent unauthorized transactions with restricted individuals, organizations, and countries. Our commitment to OFAC compliance is not only a legal obligation but also an ethical responsibility to protect the integrity of the global financial system.

With a robust screening process, efficient reporting mechanisms, and continuous monitoring and review, Zil Money strives to set the benchmark in OFAC compliance. This manual will provide insights into our screening methodologies, escalation procedures for hits, recordkeeping practices, and employee training to ensure that all stakeholders are well-informed and aligned with our mission to maintain a secure and compliant financial ecosystem.

POLICY STATEMENT:

Zil Money’s commitment to OFAC compliance is underpinned by a comprehensive policy that emphasizes accuracy, efficiency, and adherence to all regulatory requirements. This section outlines our core principles guiding the screening and reporting processes, ensuring transparency and integrity in our operations.

(a) Commitment to OFAC Compliance:

Zil Money is steadfast in its commitment to maintaining full compliance with the regulations set forth by the Office of Foreign Assets Control (OFAC). We recognize the critical role OFAC plays in safeguarding the integrity of the global financial system and preventing illicit activities, including money laundering and terrorist financing. Our commitment to OFAC compliance extends across all levels of our organization, from senior management to every employee, as we strive to uphold the highest standards of integrity and transparency.

(b) Principles of Screening and Reporting:

Our screening and reporting processes are guided by a set of core principles that prioritize accuracy, efficiency, and due diligence. We utilize advanced technology tools and integration with the MOOV Watchman API to conduct real-time screenings during user login and monthly checks to identify potential OFAC matches. Our team of experienced investigators conducts thorough investigations of hits, ensuring timely and appropriate resolution. We recognize that false positives may occur, and as such, we maintain protocols to verify and validate hits before taking any action, preventing unnecessary disruptions to legitimate transactions.

Zil Money is fully committed to adhering to all relevant laws, rules, and regulations concerning OFAC compliance. We conduct regular reviews of our screening procedures to ensure they are in line with current regulatory requirements and industry best practices. Our policies and procedures are designed to keep pace with the changing regulatory landscape, enabling us to continuously enhance the accuracy and effectiveness of our screening and reporting measures.

In conclusion, Zil Money’s Policy Statement reflects our unwavering dedication to maintaining strict OFAC compliance. Our commitment is driven by the understanding that effective screening and reporting measures are essential to protect the financial system from illicit activities. We continuously strive to exceed regulatory expectations and industry standards, positioning ourselves as a trusted and compliant fintech platform in the payment processing industry.

SCREENING PROCESS:

The screening process at Zil Money is a crucial aspect of our commitment to OFAC compliance. This section outlines the various components of our screening process, which is designed to be efficient, accurate, and in full compliance with relevant laws, rules, and regulations.

(a) Real-time Screening at Login:

To ensure immediate identification of potential OFAC matches, Zil Money conducts real-time screening during user login to our platform. This proactive approach allows us to prevent unauthorized transactions with restricted individuals or entities from the outset. By integrating advanced technology tools and APIs, we can quickly compare user information against the OFAC sanctions list and generate alerts for further review if needed.

(b) Frequency of OFAC Checks:

In addition to real-time screening at login, Zil Money conducts regular monthly checks on all users, vendors, and transactions. This periodic review ensures that our database is up-to-date and aligned with the latest OFAC sanctions list. Regular checks are essential in promptly identifying any new hits that may have occurred since the last screening. Additionally, ad hoc screenings are performed as needed based on specific transactional risks to further enhance our screening process.

While our automated screening tools are highly effective, we recognize the potential for false positives. To address this, we have established a manual verification process conducted by our experienced investigation team. When a potential OFAC match is generated, our investigators conduct thorough research and analysis to validate the hit before taking any action. This meticulous verification process ensures that legitimate transactions are not unduly affected.

(d) Use of Technology Tools and APIs:

Zil Money leverages technology to optimize our screening process. Integration with the MOOV Watchman API allows us to seamlessly transmit user information for screening against the OFAC sanctions list. Additionally, we utilize other advanced technology tools to enhance fraud detection and ID verification, ensuring a secure and compliant environment for our users.

To sum up, Zil Money’s Screening Process is a well-orchestrated combination of real-time screening at login, regular monthly checks, manual verification, and cutting-edge technology integration. This comprehensive approach is in strict compliance with relevant regulatory requirements and industry best practices, enabling us to uphold the highest standards of OFAC compliance and maintain the integrity of our financial ecosystem.

REPORTING MECHANISMS:

At Zil Money, we place great emphasis on effective reporting mechanisms to promptly communicate potential OFAC hits and ensure compliance with relevant laws, rules, and regulations. This section outlines our reporting processes, which prioritize timely and accurate reporting to regulatory authorities, banking partners, and service partners.

(a) Reporting to Regulatory Authorities:

In strict adherence to regulatory requirements, Zil Money promptly reports any suspected OFAC violations to the relevant regulatory authorities. We maintain detailed records of each reported case, including the names and addresses of the parties involved, the nature of the suspected violation, and any other relevant information. By promptly and accurately reporting to regulatory authorities, we play an active role in preventing financial crimes and safeguarding the integrity of the financial system.

(b) Reporting to Banking and Service Partners:

We maintain a transparent and collaborative relationship with our banking and service partners by promptly reporting any OFAC hits or potential violations. Our proactive approach allows our partners to be well-informed and take necessary actions based on the reported information. Through regular communication channels, including emails and secure portals, we keep our partners updated on flagged users and transactions, ensuring a proactive response to potential risks.

In addition to reporting, Zil Money provides panel access to our banking partners for direct monitoring of users or transactions flagged by our screening process. This direct monitoring capability enables our partners to actively observe any OFAC matches and conduct their own reviews and investigations. Panel access fosters a collaborative effort in ensuring compliance and risk management, strengthening our partnership with banking and service entities.

As outlined above, Zil Money’s reporting mechanisms are characterized by timely and accurate reporting to regulatory authorities, banking partners, and service partners. By upholding transparency and effective communication, we contribute to a secure and compliant financial ecosystem. Our commitment to reporting aligns with relevant regulatory requirements and industry best practices, reaffirming our dedication to maintaining the highest standards of OFAC compliance.

ESCALATION AND INVESTIGATION:

Zil Money’s Escalation and Investigation process plays a critical role in ensuring the accuracy and efficiency of our OFAC compliance efforts. This section outlines the protocols for handling OFAC hits, the involvement of senior management, and our commitment to timely resolution.

(a) Protocol for Handling OFAC Hits:

When a potential OFAC hit is generated during our screening process, Zil Money follows a well-defined protocol for investigation and resolution. Our experienced investigation team conducts thorough research and analysis to validate the hit’s accuracy before taking any further action. This includes reviewing additional data, conducting interviews, and consulting external resources when necessary. We understand the gravity of potential OFAC hits, and our protocol ensures that all necessary steps are taken to avoid any undue disruptions to legitimate transactions.

(b) Involvement of Senior Management:

At Zil Money, we prioritize the involvement of senior management in addressing potential OFAC hits. If a hit requires escalation, it is promptly brought to the attention of senior management for further review and decision-making. Their involvement ensures that critical decisions are made with a comprehensive understanding of the situation and in compliance with relevant laws and regulations. Senior management’s oversight reinforces our commitment to maintaining the highest standards of OFAC compliance.

We recognize the significance of timely resolution when addressing potential OFAC matches. Our investigation team works diligently to ensure that each hit is promptly and appropriately addressed. The team is well-trained and equipped to handle investigations efficiently, striking a balance between accuracy and speed. Our commitment to timely resolution extends to promptly communicating outcomes to relevant stakeholders, including banking partners and customers, to maintain transparency and compliance.

Zil Money’s Escalation and Investigation process is characterized by a well-defined protocol, the involvement of senior management, and a commitment to timely resolution. Our systematic approach ensures that potential OFAC hits are thoroughly investigated and validated before any action is taken, promoting confidence and trust in our compliance efforts.

RECORD KEEPING:

Effective record-keeping is a cornerstone of Zil Money’s OFAC compliance program. This section outlines our record-keeping practices, which are designed to adhere to relevant laws, rules, and regulations while ensuring the secure and accessible storage of OFAC-related records.

(a) Retention of OFAC-Related Records:

Zil Money maintains complete and accurate records of all OFAC-related activities for a minimum period of five years, as required by regulatory requirements. These records include details of screenings, investigation outcomes, reported hits, and any relevant communication with regulatory authorities, banking partners, or service partners. Our commitment to retaining records for the required duration ensures that we can respond promptly to any inquiries and cooperate with authorities during inspections.

(b) Secure Storage of Records:

The security of our records is of paramount importance to us. Zil Money employs robust information security measures to protect OFAC-related records from unauthorized access, loss, or tampering. These records are stored in secure databases and servers, with access restricted to authorized personnel only. By implementing industry-leading data security practices, we safeguard the confidentiality and integrity of our recordkeeping process.

Zil Money maintains a proactive approach to inspections by ensuring that OFAC-related records are readily accessible for inspection by regulatory authorities. We cooperate fully with any inspection requests, promptly providing the necessary records and information. Our commitment to transparency extends to making records available to our banking and service partners when required, fostering a collaborative and compliant approach.

Our record-keeping practices are guided by the principle of adherence to relevant laws, rules, and regulations, as well as industry best practices. We retain records for the prescribed duration and ensure their secure storage to protect against unauthorized access.

EMPLOYEE TRAINING AND AWARENESS:

Zil Money recognizes that a well-trained and aware workforce is integral to maintaining robust OFAC compliance. This section outlines our comprehensive employee training and awareness program, which ensures that our team is equipped to adhere to relevant laws, rules, and regulations while staying updated on any regulatory changes.

(a) Training on OFAC Compliance:

At Zil Money, all employees undergo rigorous training on OFAC compliance as part of their onboarding process. This training includes an in-depth understanding of OFAC regulations, the importance of compliance, and the company’s policies and procedures for screening and reporting. Employees are educated on the significance of their role in detecting and preventing potential OFAC violations, fostering a culture of compliance throughout the organization.

Our training sessions are regularly updated to incorporate the latest developments in OFAC compliance and industry best practices. We ensure that employees are aware of the consequences of non-compliance and the impact it can have on both the company and its customers. By empowering our workforce with the knowledge and skills necessary for OFAC compliance, we strengthen our defense against potential risks and reinforce our commitment to ethical business practices.

(b) Updates on Regulatory Changes:

Zil Money maintains a proactive approach to keeping employees informed about any regulatory changes related to OFAC compliance. We conduct periodic workshops and training sessions to update employees on amendments to OFAC regulations, changes in screening methodologies, and any additional reporting requirements. By staying abreast of regulatory developments, our employees can confidently navigate potential challenges and maintain the highest standards of compliance.

Additionally, our compliance team regularly disseminates relevant information through internal communications channels, ensuring that employees have timely access to the latest guidance and best practices. This open and transparent approach encourages a culture of continuous learning and reinforces our dedication to compliance excellence.

THIRD-PARTY SERVICE PROVIDERS:

Zil Money recognizes the importance of robust due diligence and oversight when engaging with third-party service providers. This section outlines our approach to managing relationships with these entities, ensuring compliance with relevant laws, rules, and regulations, and upholding industry best practices.

(a) Due Diligence for Third-Party Providers:

Before engaging with any third-party service provider, Zil Money conducts comprehensive due diligence to ensure they meet our stringent compliance standards. This due diligence process includes a review of the provider’s background, reputation, and compliance history. We also assess the provider’s adherence to OFAC regulations and other relevant laws.

During the due diligence process, we identify any potential risks associated with the third-party provider, including their relationship with sanctioned individuals or entities. By conducting thorough due diligence, we mitigate the risks of dealing with non-compliant entities and strengthen our commitment to a compliant financial ecosystem.

(b) Contractual Requirements for Compliance:

Zil Money includes explicit provisions in contracts with third-party service providers that mandate compliance with OFAC regulations and other relevant laws. These contractual requirements emphasize the importance of adherence to sanctions and embargoes, and they oblige providers to promptly report any potential OFAC violations.

By incorporating compliance requirements in our contracts, we foster a culture of responsibility and accountability among our third-party partners. These contractual provisions also enable us to take appropriate action in case of non-compliance, reinforcing our commitment to maintaining a secure and compliant payment processing platform.

Our commitment to compliance extends beyond the initial engagement with third-party service providers. Zil Money conducts regular monitoring and reviews of our third-party partners to ensure ongoing compliance with OFAC regulations and other requirements.

Through periodic reviews, we assess the effectiveness of the provider’s compliance program and their handling of OFAC-related incidents. This proactive monitoring approach allows us to promptly identify any changes in the provider’s status or compliance practices, taking necessary actions as needed to mitigate potential risks.

Zil Money’s approach to third-party service providers emphasizes due diligence, contractual requirements for compliance, and regular monitoring and review. By holding our partners to the same high compliance standards we set for ourselves, we maintain a secure and compliant payment processing ecosystem. Our commitment to transparency and oversight reflects our dedication to being a responsible and trustworthy fintech platform in the industry.

INTEGRATION WITH INDUSTRY TOOLS:

Zil Money recognizes the significance of leveraging advanced industry tools to enhance our OFAC compliance capabilities. This section outlines our integration with industry-leading tools and technologies that bolster our screening and fraud detection processes, ensuring a robust and efficient compliance program.

(a) Integration with MOOV Watchman API:

Zil Money has strategically integrated its system with the MOOV Watchman API to streamline our OFAC screening process. This direct API connection enables seamless transmission of user details to MOOV Watchman for screening against the OFAC database. By leveraging the capabilities of MOOV Watchman, we ensure real-time screening during user login, allowing us to promptly identify any OFAC matches and prevent unauthorized transactions.

(b) Additional Fraud Detection Tools:

In addition to MOOV Watchman, Zil Money employs additional industry tools for comprehensive fraud detection. Tools like Sift, IP Quality Score, and Persona enhance our ability to assess and identify potentially fraudulent activities. These tools analyze various aspects of user behavior, device information, and transactional patterns to assign fraud scores and detect suspicious activities promptly.

The integration of these tools allows us to stay one step ahead in combating financial crimes, protecting both our customers and the financial system as a whole.

As part of our due diligence process, Zil Money utilizes ID verification tools to ensure the authenticity of user information. This includes validating user IDs and conducting selfie authentication to verify user identities.

By implementing robust ID verification measures, we strengthen our ability to identify potential risks and maintain a secure and compliant platform.

MONITORING AND REVIEW:

Zil Money is committed to maintaining a proactive approach to monitoring and reviewing our OFAC compliance procedures. This section outlines our systematic approach to regularly assess our compliance processes, adhere to industry best practices, and continuously improve our OFAC screening and reporting mechanisms.

(a) Regular Review of Compliance Procedures:

At Zil Money, we conduct regular reviews of our OFAC compliance procedures to ensure their effectiveness and alignment with regulatory requirements. Our compliance team performs internal audits, examining the accuracy and efficiency of our screening processes and reporting mechanisms.

These reviews enable us to identify any potential gaps or areas for improvement, allowing us to take prompt corrective actions and strengthen our overall compliance program.

(b) Adherence to Industry Best Practices:

Zil Money is committed to benchmarking our compliance practices against industry best practices. We stay abreast of the latest developments in OFAC compliance and continuously evaluate our procedures to ensure they align with the most current and effective approaches.

By adhering to industry best practices, we demonstrate our commitment to maintaining a robust and forward-looking compliance framework, safeguarding our customers and partners from potential risks.

As part of our dedication to excellence, we embrace a culture of continuous improvement. Zil Money encourages feedback from employees, partners, and regulatory authorities to identify opportunities for enhancing our OFAC screening and reporting processes.

We use this feedback to implement targeted improvements, streamline our procedures, and enhance the accuracy and efficiency of our compliance mechanisms.

CONCLUSION:

Zil Money’s commitment to maintaining a secure and compliant payment processing ecosystem is reflected in our comprehensive OFAC screening and reporting measures. This manual outlines the key elements of our compliance program, which is designed to align with relevant laws, rules, and regulations while adhering to industry best practices.

OFAC SCREENING AND REPORTING MANUAL

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