SX
street x
Compliance Policy

Anti-Money Laundering
(AML) Policy

Last Updated: January 1, 2025

This Anti-Money Laundering Policy ("AML Policy") sets forth the compliance framework of Street X Inc with respect to the requirements of the Bank Secrecy Act (BSA), 31 U.S.C. § 5311 et seq., and the regulations promulgated thereunder by the Financial Crimes Enforcement Network (FinCEN), including 31 CFR Part 1022, as applicable to our payment agency services.

1. Policy Statement

Street X Inc is committed to full compliance with all applicable anti-money laundering laws and regulations. It is the policy of Street X Inc that the company will not knowingly facilitate money laundering, terrorist financing, or any other illegal financial activity. This AML Policy applies to all employees, officers, and agents of Street X Inc and governs all aspects of our payment agency operations.

2. AML Compliance Program

Our AML compliance program is designed to include the following components as required by 31 CFR § 1022.210:

A. Internal Policies, Procedures, and Controls

Street X Inc maintains written policies and procedures designed to prevent money laundering and terrorist financing. These policies address the specific risks associated with our payment agency services and are reviewed and updated on a regular basis.

B. Compliance Oversight

Street X Inc designates a compliance officer responsible for overseeing the day-to-day implementation of this AML Policy, ensuring adherence to applicable requirements, and serving as the primary point of contact for compliance matters.

C. Employee Training

All employees involved in payment operations or client-facing activities are required to receive training on AML requirements, including how to identify and escalate potentially suspicious activity. Training is conducted on a regular basis and updated to reflect changes in applicable law.

D. Independent Review

This AML Policy and its implementation are subject to periodic independent review to assess effectiveness and identify areas for improvement. Findings are reported to senior management and used to update the program as appropriate.

3. Customer Identification and Due Diligence

It is the policy of Street X Inc to conduct customer identification and due diligence prior to establishing any business relationship. Our customer identification policy requires:

  • —Verification of client identity through appropriate documentation before providing services
  • —Assessment of the nature and purpose of each client's business relationship with us
  • —Identification of beneficial owners of legal entity clients as required by applicable regulation
  • —Enhanced review procedures for relationships presenting higher risk indicators
  • —Ongoing monitoring of client relationships and transaction patterns

4. Transaction Monitoring and Reporting

Our policy requires monitoring of transactions for potentially suspicious activity. Where suspicious activity is identified and meets applicable reporting thresholds, our policy requires:

  • —Filing of Suspicious Activity Reports (SARs) with FinCEN within the timeframes required by 31 CFR § 1022.320
  • —Filing of Currency Transaction Reports (CTRs) for applicable cash transactions as required by 31 CFR § 1010.311
  • —Screening of transactions and counterparties against OFAC sanctions lists prior to processing
  • —Retention of all transaction records for the periods required by applicable BSA regulations

5. Indicators of Suspicious Activity

Our employees are trained to recognize and escalate the following indicators of potentially suspicious activity, among others:

  • —Transactions that appear to have no apparent legitimate business purpose
  • —Transaction patterns inconsistent with a client's stated business or prior activity
  • —Apparent attempts to structure transactions to avoid reporting thresholds
  • —Clients who are reluctant to provide required identification or business information
  • —Transactions involving parties or jurisdictions subject to applicable sanctions
  • —Rapid movement of funds through accounts without apparent business justification

6. Recordkeeping

Our recordkeeping policy requires the retention of all records required by the BSA and its implementing regulations, including transaction records, customer identification information, and compliance-related documentation. Records are to be retained for a minimum of five (5) years and made available to regulatory authorities upon lawful request.

7. Compliance Contact

Compliance Department
Street X Inc
2840 Keller Springs Rd, Suite 903
Carrollton, TX 75006-4876
United States
[email protected]