Anti-Money Laundering (AML) Policy

1. Institutional Policy Statement

East Trust Holdings Premier Financial Services ("East Trust Holdings") is categorically committed to preventing its financial infrastructure, payment gateways, and balance sheets from being utilized to facilitate money laundering, terrorist financing, sanctions evasion, or other illicit financial maneuvers. We enforce a zero-tolerance policy regarding willful non-compliance.

2. Governing Regulatory Framework

Our AML and Counter-Terrorist Financing (CTF) program is architected pursuant to strict federal mandates, including:

• The Bank Secrecy Act (BSA) of 1970 (31 U.S.C. 5311 et seq.).
• Title III of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act (USA PATRIOT Act) of 2001.
• Directives and sanction lists administered by the Office of Foreign Assets Control (OFAC).
• Financial Crimes Enforcement Network (FinCEN) regulations and beneficial ownership mandates.

3. Customer Due Diligence (CDD)

Under our mandatory Customer Identification Program (CIP), no account is established without positive verification of identity:

• Natural Persons: Verification of legal name, physical address, date of birth, and taxpayer identification numbers (SSN/ITIN) against government databases.
• Legal Entities: Identification of corporate formation documents, good standing status, and disclosure of all Ultimate Beneficial Owners (UBOs) holding a 25% or greater equity interest.

4. Enhanced Due Diligence (EDD)

Accounts presenting heightened risk characteristics — such as Politically Exposed Persons (PEPs), cross-border correspondent accounts, cash-intensive businesses, or non-resident entities — undergo Enhanced Due Diligence. This requires detailed source-of-wealth verification, senior management approval, and abbreviated monitoring review cycles.

5. Automated Transaction Monitoring

East Trust Holdings employs machine learning algorithms and heuristic anomaly filters that scan every deposit, wire transfer, card charge, and internal transfer in real time. Transactions departing from established client baselines, rapid structuring beneath reporting thresholds, or transactions involving sanctioned jurisdictions are flagged immediately.

6. Suspicious Activity Reports (SARs)

In compliance with 31 CFR 1020.320, East Trust Holdings files a Suspicious Activity Report (SAR) with FinCEN when transactions indicate potential money laundering or tax evasion. Under strict federal law (31 U.S.C. 5318(g)(2)), East Trust Holdings employees and officers are strictly prohibited from notifying any subject or third party that a SAR has been prepared or submitted ("anti-tipping off").

7. Currency Transaction Reports (CTRs)

East Trust Holdings electronically files a Currency Transaction Report (CTR) for each deposit, withdrawal, exchange of currency, or other payment or transfer by, through, or to East Trust Holdings which involves physical currency of more than $10,000 in aggregate across a single business day.

8. Record Retention Mandate

Pursuant to BSA rules, all KYC documents, customer identity copies, transaction ledgers, wire transfer authorizations, and compliance files are retained in secure, immutable storage for a minimum period of five (5) years following account termination.

9. Employee Training Programs

All East Trust Holdings staff undergo mandatory, audited AML/BSA training on an annual basis, tailored to specific departmental roles. Refresher courses are administered whenever new federal or international sanctions are enacted.

10. AML Compliance Officer

East Trust Holdings has designated a dedicated Chief Anti-Money Laundering Officer who reports directly to the Board of Directors with independent authority to enforce policy standards. Inquiries regarding AML verification may be directed to: