Information about Seneri

AML/CTF Policy

1. Introduction

At Seneri, we are committed to complying with all applicable Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations. This policy outlines the procedures and internal controls implemented to prevent our platform from being used for money laundering or terrorism financing activities. We take a proactive approach in identifying and mitigating risks while ensuring that our users maintain a secure and compliant environment.

2. Scope

This AML/CTF Policy applies to all employees, users (both buyers and sellers), and third-party service providers involved with Seneri. The policy is applicable to all transactions carried out on our platform, including payments, shipping, and refunds.

3. Objectives

• Prevent the use of Seneri for money laundering or financing of terrorism.
• Establish clear guidelines for identifying and reporting suspicious activities.
• Ensure that Seneri complies with local and international AML/CTF regulations.
• Foster a culture of compliance and due diligence across the platform.

4. Roles and Responsibilities

• Compliance Officer: Seneri appoints a dedicated Compliance Officer responsible for implementing and monitoring the AML/CTF program. The officer ensures the company remains compliant with all applicable laws and regulations.
• Management: Senior management ensures sufficient resources are available for the effective implementation of this policy.
• Employees and Users: All employees and users of the platform must comply with this policy and report any suspicious activities to the Compliance Officer.

5. Customer Due Diligence (CDD)

To prevent money laundering and terrorism financing, Seneri conducts thorough Customer Due Diligence (CDD), especially in cases where:

• A transaction exceeds a certain threshold, to be determined by Seneri.
• A suspicious activity is detected.
• A user is from a high-risk jurisdiction.

CDD Procedures:

1. User Identification: Users must provide valid identification when creating an account. This may include name, address, contact details, and government-issued ID.
2. Verification: We may use third-party services or manual checks to verify user information before allowing large transactions to proceed.
3. Ongoing Monitoring: We conduct continuous monitoring of user transactions to detect suspicious patterns and flag high-risk activities.

6. Know Your Customer (KYC)

Seneri will implement a KYC process as part of the onboarding process for users (both buyers and sellers). The steps include:

• Basic Information Collection: Full name, date of birth, email, phone number, and billing/shipping addresses.
• Government ID Verification: For sellers who cross certain transaction thresholds or are flagged by risk assessments, additional verification such as a government-issued ID or other supporting documentation may be required.

7. Transaction Monitoring

Seneri monitors all transactions on the platform to detect suspicious activities. This includes:

• Threshold Monitoring: Transactions exceeding a certain value will be flagged for review.
• Pattern Monitoring: Unusual transaction patterns such as repeated large payments, multiple small transactions, or inconsistent shipping practices may trigger a review.
• Geographical Monitoring: Transactions involving users or shipping addresses in high-risk regions or sanctioned countries will be closely scrutinized.

8. Reporting Suspicious Activities

All Seneri employees and users are required to report suspicious activities that may involve money laundering or terrorism financing. This can include:

• Transactions that appear to have no legitimate purpose.
• Attempts to conceal the identity of users.
• Use of the platform for high-risk items that could be associated with illicit activities.

Reporting Process:

1. Employees and users must report any suspicious activity to the Compliance Officer.
2. The Compliance Officer will investigate the report and, if deemed necessary, will file a Suspicious Activity Report (SAR) with the relevant regulatory authorities.
3. All reports and investigations will remain confidential.

9. Record Keeping

Seneri will maintain records of user identification, transaction history, and any suspicious activity reports for a minimum of 5 years or as required by local regulations. This ensures that we can provide evidence if needed by regulatory authorities or law enforcement.

10. Risk Assessment

We regularly assess the risks of money laundering and terrorism financing on the platform. This includes evaluating:

• The types of transactions carried out on Seneri.
• The regions in which users operate.
• The types of products being traded.

Based on the findings, we will update our policies and controls to mitigate any identified risks.

11. Sanctions and High-Risk Countries

Seneri does not conduct business with individuals or entities from countries sanctioned by international regulatory bodies, such as the United Nations, European Union, or United States Office of Foreign Assets Control (OFAC). All users and transactions linked to high-risk countries or entities will be subject to enhanced due diligence procedures.

12. Training and Awareness

All Seneri employees involved in transaction processing, customer support, and compliance will receive regular training on AML/CTF regulations and how to identify and report suspicious activity. This ensures that our team stays informed and vigilant.

13. Penalties for Non-Compliance

Failure to comply with the AML/CTF policy may result in disciplinary action, account suspension, or legal consequences. Users found engaging in fraudulent or illegal activities may be reported to the relevant authorities.

14. Review and Updates

This AML/CTF policy will be reviewed annually or when significant regulatory changes occur to ensure that it remains compliant with local and international standards. Any changes will be communicated to all relevant stakeholders.