AML Policy

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It is our policy to comply with all government regulations at all times. As a money service business, we are subject to the following regulations:

REPORTING

We are required to report the following types of transactions to the authorities:

• Suspicious Activity (SAR)
• Currency Transactions (CTR)

RECORD KEEPING

We are required to keep all client, transaction and corporate records for a minimum of 5 years.

ASCERTAINING IDENTITY

We are required to collect and verify your identification for remittances of $3,000 and more.

POLITICALLY EXPOSED PERSON (PEP)

We are required to make PEP determination for transactions that have any ties to politically exposed persons.

THIRD PARTY DETERMINATION

Shaka Express Corp policy not to accept 3rd party transaction.

COMPLIANCE PROGRAM

We are required to maintain a compliance program containing adequate policies and procedures in accordance with the applicable regulations.

For more information, refer to FINCEN Website:

http://www.fincen.gov/financial_institutions/msb/

ADDITIONAL MEASURES WE TAKE TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING

WE TAKE THE FOLLOWING ADDITIONAL MEASURES TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING:

SCANNING AGAINST THE HM TREASURY WATCH LIST

It is our policy to check each transaction against the HM Treasury watch list. Any matched names are subject to further review by the compliance officer.

TRANSACTION MONITORING

We have adequate controls pertaining to the transaction activity at several instances of the life cycle of a transaction. These controls include:

• Client Profiling
• Risk Assessment
• Client Identification Controls & Validations
• Transaction Aggregation Thresholds
• Government Reporting Controls & Validations
• Possible Structuring Reporting
• Enhanced Due Diligence Reporting