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.

PROHIBITED COUNTRIES: POLICIES, PROCEDURES AND STRATEGIES

INTRODUCTION:

At Zil Money, we are committed to maintaining the highest standards of compliance and security in our operations. This Prohibited Countries Manual serves as a comprehensive guide outlining our policies, procedures, and strategies concerning transactions with prohibited countries under the Office of Foreign Assets Control (OFAC) and other relevant authorities. Our dedication to compliance is aligned with industry-standard international best practices, ensuring transparency and trust among our stakeholders.

(a) Purpose of the Manual:

The purpose of this manual is to provide a clear and concise framework that enables Zil Money to identify and mitigate risks associated with prohibited countries. It outlines our approach to complying with all relevant legal and regulatory requirements, particularly those pertaining to OFAC and other authorities. By adhering to this manual, we aim to safeguard our platform from potential financial crimes and reinforce our commitment to ethical practices.

(b) Scope and Applicability:

This manual applies to all aspects of Zil Money’s operations that involve customer transactions and interactions. It extends to our partnerships with banking and service providers who support our services, as well as to our employees responsible for implementing the procedures outlined herein. The scope of this manual encompasses customer onboarding, transaction screening, ongoing monitoring, and compliance reviews to ensure comprehensive risk management.

Zil Money’s Prohibited Countries Manual is designed to comply with all applicable legal and regulatory requirements, including OFAC sanctions and other relevant authorities’ directives. Our commitment to upholding the highest industry standards is demonstrated through the utilization of advanced compliance tools and robust risk assessment procedures. This manual provides a framework that aligns with the latest developments in the fintech industry, ensuring we maintain a proactive stance against prohibited activities.

As we embark on this journey to ensure adherence to the Prohibited Countries Manual, we prioritize the safety and integrity of our platform, our customers, and our partnerships. By maintaining transparency and a proactive approach to compliance, we aim to foster trust and confidence among our stakeholders, affirming our position as a responsible and compliant fintech platform in the payment processing industry.

PROHIBITED COUNTRIES POLICY:

This Manual outlines Zil Money’s approach to maintaining a secure and compliant environment by identifying countries subject to sanctions and restrictions, including those imposed by the OFAC and other relevant international bodies. We prioritize the prevention of engagement with entities from prohibited countries to mitigate potential risks related to money laundering, terrorist financing, and other illicit activities.

a) Overview of Prohibited Countries:

In accordance with industry-standard international best practices, the Prohibited Countries Policy of Zil Money encompasses a comprehensive list of countries subject to economic sanctions, trade restrictions, or other prohibitions by various authorities, including the Office of Foreign Assets Control (OFAC) and other relevant international bodies. This section provides an overview of the policy’s purpose and its role in mitigating potential risks related to money laundering, terrorist financing, and other illicit activities associated with prohibited countries.

(b) Compliance with OFAC and Other Authorities:

At Zil Money, strict compliance with all applicable laws, rules, and regulations issued by the OFAC and other relevant authorities concerning transactions with prohibited countries is of utmost importance. This subsection elaborates on our commitment to continuous monitoring and screening of customer transactions against updated sanctions lists and watchlists. By adhering to the guidelines set forth by regulatory authorities, Zil Money upholds a proactive and vigilant approach to mitigating risks associated with prohibited countries.

The Prohibited Countries Policy is guided by a set of core objectives and principles aimed at maintaining a secure and compliant environment. This section outlines the primary policy objectives, including preventing any engagement with entities from prohibited countries and enhancing due diligence procedures. The principles of transparency, integrity, and responsibility govern our approach, fostering a risk-aware culture where employees and partners contribute to the policy’s effective implementation.

(d) Prohibited Countries List:

Central to the Prohibited Countries Policy is a regularly updated list of countries subject to sanctions or restrictions. Our dedicated compliance team is responsible for maintaining this list, aligning it with the latest OFAC designations and other relevant authorities’ notifications. This subsection details the importance of this list and how it forms the basis for our risk assessment procedures. Prompt actions are taken to block transactions involving entities from prohibited countries to ensure compliance with regulatory requirements.

RISK ASSESSMENT AND DUE DILIGENCE:

This section outlines Zil Money’s comprehensive risk assessment and due diligence procedures, reflecting our commitment to identifying and managing risks associated with transactions involving prohibited countries.

(a) Risk-Based Approach to Prohibited Countries:

Zil Money adopts a risk-based approach to assess and manage transactions with prohibited countries. This entails categorizing countries based on their risk levels, taking into account various factors such as the severity of sanctions, geopolitical landscape, and historical compliance records. By utilizing this approach, we tailor our due diligence procedures to prioritize resources on high-risk countries, ensuring a targeted and efficient risk management strategy.

(b) Customer Risk Profiling:

To enhance risk assessment, Zil Money employs customer risk profiling that evaluates the risk associated with individual customers. This involves considering factors such as customer background, transaction patterns, and the countries with which they engage in business. The risk profile assists in determining the level of scrutiny required for customer transactions and interactions, allowing us to allocate resources effectively to manage potential risks.

For transactions involving customers from high-risk countries or those classified as high-risk individuals, Zil Money implements Enhanced Due Diligence (EDD). This involves conducting more comprehensive and in-depth investigations, verifying the legitimacy of the transaction, and validating the identities of involved parties. The EDD process ensures a thorough understanding of the transaction’s purpose and mitigates the potential risks associated with high-risk entities.

PROHIBITED COUNTRIES SCREENING PROCEDURES:

This section outlines the rigorous screening procedures implemented by Zil Money to ensure compliance with sanctions lists and watchlists, aiming to prevent any engagement with entities from prohibited countries.

(a) Screening Against Sanctions Lists:

Zil Money utilizes advanced technology and resources to conduct real-time screening of customer transactions against relevant sanctions lists, including those issued by the OFAC and other authorities. This screening process is designed to promptly identify and block any transactions involving individuals, entities, or countries subject to economic sanctions or trade restrictions.

(b) Watchlist Screening:

In addition to sanctions lists, Zil Money performs watchlist screening to monitor potential matches with entities considered high-risk or involved in suspicious activities. These watchlists are sourced from various reputable databases and provide an extra layer of scrutiny to identify any potential threats or risks associated with customer transactions.

Screening procedures are conducted on a regular basis to ensure continuous monitoring of customer transactions and account activities. New customer onboarding and existing account updates trigger immediate screening against sanctions lists and watchlists. Additionally, ongoing monitoring of customer accounts ensures that any changes in risk profiles are promptly assessed, enabling timely risk management measures.

(d) False Positives Handling:

To avoid unnecessary disruptions and false alerts, Zil Money has established protocols for handling potential matches flagged during screening. Our dedicated compliance team thoroughly investigates flagged matches to determine their legitimacy. False positives are carefully distinguished from genuine matches, and appropriate actions are taken accordingly. This ensures that legitimate transactions are not unduly blocked, maintaining a seamless payment processing experience for our customers.

Zil Money maintains the regularly updated list of prohibited countries, products and services at this weblink: https://zilmoney.com/prohibited-countries-products-services.

BLOCKED TRANSACTIONS AND ESCALATION:

This section outlines Zil Money’s procedures for blocking transactions involving prohibited countries and the protocols for escalating potential matches to ensure timely and appropriate actions are taken.

(a) Blocking Transactions from Prohibited Countries:

Zil Money employs robust measures to automatically block transactions originating from or destined to prohibited countries. Our advanced screening technology, in line with OFAC and other relevant authorities’ sanctions lists, promptly identifies and prevents any attempts to conduct transactions involving restricted entities or countries. This proactive approach ensures that prohibited transactions are intercepted and blocked in real-time, safeguarding the integrity of our platform and maintaining compliance with regulatory requirements.

(b) Escalation Protocols for Potential Matches:

In the event of potential matches flagged during screening, Zil Money has established well-defined escalation protocols. Our compliance team conducts thorough reviews of the flagged matches, ensuring proper due diligence is exercised. If necessary, the compliance team collaborates with other relevant stakeholders to assess the legitimacy of the match and determine the appropriate course of action. This escalation process ensures that potential risks are diligently assessed, enabling timely and accurate decisions.

Zil Money is committed to fulfilling its obligations in reporting any confirmed matches with sanctions lists or suspicious activities to the relevant authorities, including the OFAC and other regulatory bodies. Our compliance team ensures that all reporting procedures are strictly adhered to and that information is provided in a timely and accurate manner. This collaboration with regulatory authorities further reinforces our commitment to combatting financial crimes and contributing to a safe and compliant financial ecosystem.

PROCEDURES FOR UPDATING PROHIBITED COUNTRIES LIST:

This section outlines the procedures implemented by Zil Money for updating the Prohibited Countries List, ensuring its accuracy and compliance with relevant laws, regulations, and international best practices.

(a) Frequency of List Updates:

Zil Money regularly reviews and updates the Prohibited Countries List to reflect changes in sanctions, trade restrictions, or other prohibitions issued by the OFAC and other relevant authorities. The frequency of updates is determined based on regulatory developments and geopolitical events. The compliance team diligently monitors any amendments to sanctions lists to promptly reflect such changes in the Prohibited Countries List.

(b) Responsibility for List Maintenance:

The responsibility for maintaining the accuracy and relevance of the Prohibited Countries List lies with Zil Money’s compliance team. This team collaborates with industry experts, legal advisors, and regulatory authorities to ensure that the Prohibited Countries List remains up-to-date and aligns with current regulatory requirements. Additionally, feedback from banking and service partners is considered during the list maintenance process.

Before implementing updates to the Prohibited Countries List, the compliance team performs a comprehensive validation and review process. This includes cross-referencing the proposed changes with official sanctions lists, verifying the accuracy of information, and assessing the potential impact of the updates on customer transactions. The validation and review process ensures that only accurate and relevant changes are incorporated into the Prohibited Countries List.

PROHIBITED COUNTRIES CUSTOMER ONBOARDING:

This section outlines the customer onboarding procedures employed by Zil Money to ensure compliance with Prohibited Countries policies and relevant regulations, emphasizing the implementation of robust KYC and KYB checks.

(a) KYC and KYB Checks for New Customers:

Zil Money conducts comprehensive Know Your Customer (KYC) and Know Your Business (KYB) checks for all new customers to verify their identities and assess their risk profiles. The KYC process involves gathering essential information and documentation from customers, such as government-issued IDs, proof of address, and other relevant details. Similarly, for business customers, the KYB process involves obtaining official registration documents, beneficial ownership information, and other relevant business details. These checks enable Zil Money to ascertain the legitimacy of customers and ensure they meet the required compliance standards before onboarding.

(b) Document Verification and Biometric Authentication:

As part of the onboarding process, Zil Money utilizes advanced document verification and biometric authentication technologies to enhance the authenticity of customer identities. Customers are required to submit scanned copies of their identification documents, which are cross-referenced with official databases and identity verification services. Additionally, biometric authentication measures, such as facial recognition or fingerprint scanning, may be employed to further validate customer identities. These verification steps contribute to a secure and reliable customer onboarding process.

To prevent potential risks associated with customers from prohibited countries, Zil Money conducts instant bank account verification. By leveraging third-party data providers, such as Yodlee, we verify the legitimacy of the provided bank account information, ensuring that customers’ financial transactions comply with relevant regulations and industry standards.

ONGOING MONITORING AND COMPLIANCE REVIEWS:

This section outlines Zil Money’s practices for continuous transaction monitoring and conducting periodic compliance reviews to ensure adherence to Prohibited Countries policies, relevant regulations, and industry best practices.

(a) Continuous Transaction Monitoring:

Zil Money employs a robust system for continuous transaction monitoring to detect any potential violations of Prohibited Countries policies in real-time. Our advanced technology and algorithms analyze customer transactions, account activities, and interactions to identify any suspicious or high-risk patterns. This ongoing monitoring allows us to promptly address any deviations from compliance standards, ensuring timely risk management measures are implemented.

(b) Periodic Compliance Reviews:

To assess the effectiveness and accuracy of our Prohibited Countries policies and procedures, Zil Money conducts periodic compliance reviews. These reviews involve comprehensive assessments of the entire compliance framework, including transaction monitoring, customer onboarding, and screening procedures. Our dedicated compliance team collaborates with external auditors and regulatory experts to conduct these reviews, ensuring an unbiased and thorough evaluation of our compliance measures.

Zil Money regularly conducts internal audits and testing of Prohibited Countries procedures to evaluate their efficiency and effectiveness. Internal audits assess the implementation of policies, adherence to regulatory requirements, and the overall compliance culture within the organization. Additionally, we conduct testing exercises to validate the accuracy and performance of screening tools and procedures. These audit and testing processes play a crucial role in identifying potential gaps and areas for improvement in our compliance framework.

CONSEQUENCES OF NON-COMPLIANCE:

This section outlines the consequences of non-compliance with Zil Money’s Prohibited Countries policies and the severity of actions taken to address policy violations.

(a) Disciplinary Measures for Policy Violations:

Zil Money maintains a stringent approach to policy compliance and addresses any violations with appropriate disciplinary measures. Employees found in violation of Prohibited Countries policies may be subject to disciplinary action, including verbal or written warnings, retraining, or other corrective actions, depending on the severity of the violation and the employee’s history of compliance.

(b) Account Suspension and Termination:

In cases where customers are found to be non-compliant with Prohibited Countries policies, Zil Money reserves the right to suspend or terminate their accounts. This action is taken to prevent any further non-compliant activities and safeguard the integrity of the platform. The decision to suspend or terminate an account is based on a thorough investigation and is in line with regulatory requirements and industry standards.

Non-compliance with Prohibited Countries policies may lead to legal implications for Zil Money, its employees, and its customers. Violations of sanctions laws and regulations can result in significant penalties, fines, or legal actions imposed by relevant authorities. Zil Money is committed to cooperating with law enforcement agencies and regulatory bodies in addressing non-compliance issues and taking appropriate actions to rectify any breaches of Prohibited Countries policies.

COLLABORATION WITH BANKING AND SERVICE PARTNERS:

This section outlines Zil Money’s commitment to collaboration with its banking and service partners to ensure seamless compliance with Prohibited Countries policies and relevant regulations.

(a) Partnership Requirements and Due Diligence:

Zil Money maintains strong collaborative relationships with its banking and service partners, ensuring mutual understanding of Prohibited Countries policies and regulatory requirements. Before entering into partnerships, Zil Money conducts rigorous due diligence on potential partners, including the completion of designated forms containing various due diligence questionnaires. Any inaccurate or false information provided by potential partners may disqualify them from further partnership consideration. This comprehensive due diligence process ensures that all partners are aligned with Zil Money’s commitment to compliance and risk management.

(b) Cooperation in Sanctions Compliance:

In collaboration with banking partners, Zil Money is dedicated to adhering to sanctions compliance requirements. The partnership entails implementing and adhering to industry-standard practices for screening customers and transactions against relevant sanctions and watchlists, including the OFAC’s Specially Designated Nationals and Blocked Persons List (“OFAC SDN List”) and other government watchlists. Timely reporting of any identified matches to relevant authorities is essential in preventing financial crimes. By working closely with banking partners, Zil Money strengthens its sanctions compliance program and ensures a robust and unified approach to managing risk.

Zil Money maintains transparency in its collaboration with banking and service partners regarding Prohibited Countries policies and risk management practices. Regular communication and sharing of information enable partners to stay updated on compliance measures and changes in the Prohibited Countries list. Additionally, Zil Money ensures timely and accurate reporting to partners and relevant authorities, facilitating effective risk mitigation and promoting a secure financial environment.

TRAINING AND AWARENESS:

This section outlines Zil Money’s comprehensive approach to employee training and awareness regarding Prohibited Countries policies and regulatory compliance.

(a) Employee Training on Prohibited Countries Policy:

Zil Money places a strong emphasis on providing thorough and ongoing training to its employees regarding Prohibited Countries policies. All employees are required to undergo training sessions that cover the scope and importance of compliance with these policies. The training includes information on identifying high-risk countries, conducting screenings, handling potential matches, and reporting suspected violations. By ensuring that employees are well-informed and educated on Prohibited Countries policies, Zil Money aims to foster a culture of compliance and risk awareness throughout the organization.

(b) Reporting Suspected Violations:

Employees are encouraged and obligated to report any suspected violations of Prohibited Countries policies promptly. Zil Money maintains a confidential reporting mechanism that allows employees to report concerns or potential breaches of compliance without fear of retaliation. The reporting process is designed to protect the confidentiality of the reporting party and facilitate the investigation of reported concerns by the compliance team. This proactive approach to reporting strengthens Zil Money’s ability to identify and address potential issues in a timely manner.

Zil Money is committed to keeping its employees informed about any updates or changes to Prohibited Countries policies. Regular communication channels, such as internal memos, email notifications, or training sessions, are used to disseminate policy updates to relevant personnel. By maintaining open and transparent communication, Zil Money ensures that employees are aware of the latest compliance requirements and can adapt their practices accordingly.

CONCLUSION:

This section summarizes Zil Money’s commitment to compliance, security, and continuous improvement in managing Prohibited Countries policies and practices.

(a) Commitment to Compliance and Security:

Zil Money reiterates its unwavering commitment to adhering to Prohibited Countries policies in full compliance with relevant laws, regulations, and industry standards. The company places a high priority on maintaining a secure and compliant platform to safeguard its users and partners from potential risks associated with prohibited countries.

(b) Continuous Improvement Initiatives:

Zil Money acknowledges the dynamic nature of the regulatory landscape and the evolving risks associated with prohibited countries. As part of its dedication to continuous improvement, the company regularly reviews and updates its Prohibited Countries policies, procedures, and strategies. Collaborative efforts with banking and service partners also contribute to enhancing the effectiveness of compliance measures and risk management.

PROHIBITED COUNTRIES: POLICIES, PROCEDURES AND STRATEGIES

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