Anti-Money Laundering (AML) Policy

1. Policy Statement

It is the policy of Sharemysub LLC (“ShareMySub”) to prohibit and actively prevent money laundering and the financing of terrorism or other criminal activities. ShareMySub is committed to full compliance with all applicable United States federal laws and regulations, including the Bank Secrecy Act (BSA), the USA PATRIOT Act, and guidance issued by the Financial Crimes Enforcement Network (FinCEN).

All officers, employees, contractors, and affiliates of ShareMySub must adhere strictly to this policy and ensure that our platform and services are not misused for illicit financial purposes.

2. Regulatory Compliance

• ShareMySub will cooperate with U.S. regulators, law enforcement agencies, and financial institutions to ensure adherence to AML/CFT (counter-terrorist financing) obligations.
• ShareMySub will implement and maintain internal monitoring mechanisms consistent with U.S. AML standards and adjust procedures to respond to evolving risks.
• ShareMySub will work with its payment processors and financial partners, who may be subject to MSB or financial-institution obligations, to ensure proper reporting and record-keeping.

3. Risk-Based Approach

• ShareMySub applies a risk-based control strategy to determine a user’s risk level, including the nature of subscriptions purchased, payment behaviour, and account activity.
• Risk assessment forms the basis for identifying abnormal or suspicious transactions.
• ShareMySub sets and enforces transaction limits and withdrawal thresholds appropriate to platform security, user history, and compliance requirements.

4. Monitoring and Detection

• ShareMySub continuously monitors transactions to identify unusual patterns or behaviours, including:
  • Excessive frequency of transactions inconsistent with user history.
  • Transaction volumes exceeding reasonable or expected limits.
  • Activity inconsistent with the stated purpose of the account.
• If a transaction is deemed suspicious, ShareMySub may:
  • Delay, suspend, or reject the transaction.
  • Restrict user access to the platform.
  • Escalate for further compliance review.

5. Reporting Obligations

• In accordance with U.S. law, ShareMySub may be required to file Suspicious Activity Reports (SARs) with FinCEN and/or cooperate with other law enforcement authorities.
• ShareMySub is prohibited by law from notifying users if such a report is filed.
• ShareMySub retains the right to refuse transactions at any stage if there is reason to suspect money laundering, terrorist financing, fraud, or other unlawful conduct.

6. Employee Responsibilities

• Employees must be trained to identify red flags, escalate concerns, and comply with AML procedures.
• Failure to adhere to this policy may result in disciplinary action, up to and including termination, and may expose the individual to civil and criminal liability.

7. Review and Updates

This policy will be reviewed annually, or more frequently as needed, to ensure compliance with evolving U.S. laws, FinCEN regulations, and best practices in AML/CFT risk management.