Anti-Money Laundering (AML) Policy

1. Introduction

IFB-INTER is committed to the highest standards of Anti-Money Laundering (AML) compliance and requires all employees to adhere to these standards to prevent use of our products and services for money laundering or terrorist financing purposes.

2. What is Money Laundering?

Money laundering is the process by which criminals disguise the original ownership and control of criminal proceeds by making such proceeds appear to come from a legitimate source.

The processes are:

• Placement - introduction of illegal funds into the financial system
• Layering - complex transactions to disguise the source
• Integration - funds re-enter the economy appearing legitimate

3. Our AML Obligations

As a regulated financial institution, IFB-INTER must:

• Implement risk-based policies and procedures
• Conduct customer due diligence (CDD)
• Monitor transactions and report suspicious activities
• Maintain records for the required period
• Provide AML training to all staff
• Cooperate with law enforcement agencies

4. Customer Due Diligence (CDD)

We conduct thorough customer due diligence for all clients, which includes:

5. Transaction Monitoring

We employ sophisticated systems to monitor transactions for suspicious patterns, including:

• Large cash transactions
• Rapid movement of funds
• Transactions with high-risk jurisdictions
• Patterns inconsistent with customer profile

6. Reporting Obligations

7. Record Keeping

We maintain comprehensive records of:

• Customer identification documents
• Transaction records
• Account files and business correspondence
• Results of any analysis undertaken

Records are retained for a minimum of 5 years after the end of the customer relationship or transaction.

8. Staff Training

All IFB-INTER employees receive regular AML training covering:

• Legal and regulatory requirements
• Money laundering techniques and trends
• Red flags and suspicious indicators
• Internal reporting procedures
• Consequences of non-compliance

9. Prohibited Activities

The following activities are strictly prohibited:

• Opening anonymous accounts or accounts under fictitious names
• Maintaining shell bank relationships
• Processing transactions when red flags cannot be resolved
• Tipping off customers about investigations

10. Compliance and Consequences

11. Contact Information

For questions about our AML policy or to report suspicious activities: