Anti-money laundering (AML) policy

The purpose of this Anti-Money Laundering (AML) Policy is to establish a comprehensive framework that ensures Brabo Innovations Inc. (“Brabo,” “we,” “us,” or “our”) complies with applicable laws and regulations aimed at preventing money laundering and terrorist financing. This policy outlines our commitment to safeguarding the integrity of our platform by implementing effective measures to detect, prevent, and report suspicious activities associated with the buying and selling of diamonds. It is designed to protect our customers, maintain trust in our services, and uphold our responsibility as a responsible market participant.

This Anti-Money Laundering (AML) Policy applies to all Sellers and Buyers engaging in transactions on the Brabo platform. It encompasses all activities related to the buying and selling of diamonds, including the processes of authentication, verification, bidding, and payment.

The objectives of this policy are to:

• Prevent Money Laundering and Terrorist Financing:

  Establish and maintain robust measures to detect and deter any attempts at money laundering or terrorist financing within our platform.

• Compliance with Legal Obligations:

  Ensure compliance with all relevant AML laws and regulations to avoid legal penalties and maintain our operational integrity.

• Promote Transparency and Integrity:

  Foster a culture of transparency and integrity by clearly outlining the responsibilities of Sellers and Buyers throughout the transaction process.

• Facilitate Effective Monitoring:

  Implement effective monitoring systems to track and analyze transactions involving Sellers and Buyers, ensuring timely detection of suspicious activities.

• Educate Stakeholders:

  Provide necessary training and resources to our employees to ensure they are equipped to recognize and address potential money laundering risks associated with diamond transactions.

• Review and Adapt:

  Regularly review and update this policy to adapt to changes in regulations, best practices, and the evolving nature of the diamond marketplace.

Brabo Innovations Inc. is committed to actively preventing money laundering and terrorist financing within the diamond trade. Our anti-money laundering policies and procedures have been designed to ensure compliance with all applicable laws, regulations, and guidelines set forth by relevant authorities, including but not limited to the Financial Crimes Enforcement Network (FinCEN) and the Bank Secrecy Act (BSA).

Brabo Innovations Inc. is committed to implementing effective Know Your Customer (KYC) procedures to verify the identities of all Sellers and Buyers engaging in transactions on our platform. The KYC process is essential to ensuring the integrity of our auction process and to comply with applicable laws aimed at preventing money laundering and terrorist financing.

• Identification Verification:

  Prior to participating in any auction, both Sellers and Buyers are required to provide valid identification documents. This may include, but is not limited to:
  • Government-issued identification (e.g., passport, driver's license)
  • Proof of address (e.g., utility bill, bank statement)

• Submission of Information:

  Sellers and Buyers must submit their identification documents through our secure platform. Brabo will review the submitted information to confirm the identity of each participant.

• Ongoing Monitoring:

  Brabo reserves the right to conduct ongoing monitoring of Seller and Buyer activity to ensure compliance with KYC requirements and to identify any unusual or suspicious behavior during the auction process.

• Refusal of Service:

  Brabo may refuse service to any Seller or Buyer who fails to provide the necessary identification or whose identity cannot be verified satisfactorily.

Brabo Innovations Inc. implements comprehensive transaction monitoring procedures to detect and prevent potential money laundering and terrorist financing activities involving Sellers and Buyers on our platform. Our monitoring processes are designed to ensure the integrity of the auction process and compliance with applicable regulations.

• Monitoring Mechanisms:

  Brabo utilizes automated monitoring systems to analyze transaction patterns, including bidding activities, payment processing, and the movement of diamonds through the auction process. This includes:
  • Tracking the history of bids placed by Buyers.
  • Monitoring payments received by Brabo for auctioned items.
  • Analyzing Seller transaction histories for any unusual activity.

• Flagging Suspicious Transactions:

  Transactions that trigger predefined risk indicators, such as unusually high bid amounts or rapid bidding patterns, will be flagged for further review. Our compliance team will conduct a thorough investigation of any flagged transactions to determine whether they warrant reporting to the appropriate authorities.

• Reporting Obligations:

  If Brabo identifies a transaction that raises suspicions of money laundering or terrorist financing, we will take appropriate action, which may include filing a Suspicious Activity Report (SAR) with relevant law enforcement agencies as required by law.

• Continuous Improvement:

  Brabo is committed to continuously improving its transaction monitoring processes to adapt to evolving risks and regulatory requirements, ensuring a secure environment for all Sellers and Buyers participating in our auctions.

Brabo Innovations Inc. is committed to maintaining comprehensive records of all transactions involving Sellers and Buyers on our platform. This includes detailed documentation of the authentication and verification processes for each diamond, as well as transaction records. The following types of records will be maintained:

1. Copies of identification documents collected during the KYC process, securely stored to protect user privacy.
2. Transaction details, including dates, amounts, and parties involved, while ensuring user anonymity is preserved throughout the documentation process.
3. Records of any reports filed regarding suspicious activities, which will be treated confidentially and in accordance with applicable laws.

We may appoint an AML Compliance Officer responsible for monitoring transactions for suspicious activity and reporting such activities to relevant authorities. This role will be critical in overseeing transactions involving anonymous bidding processes and ensuring compliance with AML regulations.

Sellers and Buyers are encouraged to report any suspicious activities or transactions to the AML Compliance Officer. We will thoroughly investigate all reports, and if necessary, file Suspicious Activity Reports (SARs) with the appropriate authorities. Sellers and Buyers must recognize that maintaining the integrity of the platform involves the responsibility to report any suspicious behavior, particularly concerning activities related to the anonymity provided by paddle numbers.

This AML Policy is subject to regular review and updates to ensure it remains compliant with evolving laws and regulations. Brabo is committed to continually improving its AML measures and adapting to new threats and challenges in the industry while ensuring the privacy and security of our users.

We are dedicated to maintaining a secure and compliant platform for buying and selling diamonds. Through the rigorous implementation of this AML Policy, we aim to prevent money laundering and terrorist financing activities while protecting the integrity of our marketplace. We reserve the right, at any time and in our sole discretion, to suspend or withdraw the right of anyone to access or use our platform if we consider that the AML Policy or KYC procedures have been abused or deemed inadequate for any specific purpose, or while we request further or replacement KYC/AML information.

For any questions or concerns regarding this AML Policy, please contact us at info@brabo.live.