Roles & Responsibilities

Management and Oversight of the AML-CTF Compliance Program The board of directors and senior management of the company have different responsibilities and roles in overseeing, and managing AML-CTF compliance risk. The board of directors has primary responsibility for ensuring that the company has a comprehensive and effective AML-CTF compliance program and oversight framework that is reasonably designed to ensure compliance with the law. Senior management is responsible for implementing the board-approved AML-CTF compliance program. Board of Directors-Senior Management The board of directors is responsible for approving the AML-CTF compliance program, the designation of a MLCO and for overseeing the structure and management of 360monex’s AML-CTF compliance function. The board is responsible for setting an appropriate culture of AML-CTF compliance, establishing clear policies regarding the management of key AML-CTF risks, and ensuring that these policies are adhered to in practice. The board ensures that senior management and the MLCO are fully capable, qualified, and properly motivated to manage the AML-CTF compliance risks arising from the organization’s business activities in a manner that is consistent with the board’s expectations. The board ensures that the function of the MLCO has an appropriately prominent status within 360monex. Senior management is responsible for communicating and reinforcing the AML-CTF compliance culture established by the board, and implementing and enforcing the board-approved AML-CTF compliance program. The MLCO reports to the board, or a senior management thereof, on the effectiveness of the AML-CTF compliance program and significant AML-CTF compliance matters. The Money Laundering Compliance Officer (MLCO) The MLCO has the appropriate authority, independence, and access to personnel and information within the company, and appropriate resources to conduct his job effectively. The board ensures that its views about the importance of AML-CTF compliance are understood and communicated across all levels of the money remittance business organization. The board also ensures that the MLCO has established appropriate incentives to integrate AML-CTF compliance objectives into management goals and compensation structure across the organization, and those corrective actions, including disciplinary measures, if appropriate, are taken when serious AML-CTF compliance failures are identified. Customer Service Employees Employees are responsible for considering the AML-CTF manual and understanding responsibilities. They ensure company procedures adhered to and obtain all documentary evidence as outlined within the AML-CTF manual. They ensure that all suspicious circumstances are reported to the MLCO and attend training as required for their role.