Monty Global Payments share the authorities’ and public’s concern regarding the link between monetary flows and criminal activity, therefore considering compliance with all regulatory controls governing the detection of and action against said activities to be a top priority. In USA: Bank Secrecy Act (“BSA”), the anti-money laundering and anti-terrorism laws and regulations promulgated by the government of the United States of America, and collectively aim to mitigate the Company’s exposure to money laundering and terrorist financing risks and to facilitate the development of an appropriate defense mechanism as reflected in its internal controls. In addition, we must consider the anti-money laundering laws and regulations, including the Currency and Foreign Transactions Reporting Act, also known as the Bank Secrecy Act (“BSA”). 31 USC  5311-5330 and 12 USC  1818(s), 1829(b), and 1951-1959; the BSA’s implementing regulations, 31 CFR 103, the Money Laundering Suppression Act; the “Drug Kingpin Law” under the Foreign Narcotics Kingpin Designation Act of 1999; Public Law 106-120, and the Money Laundering and Financial Crimes Strategy Act of 1998, Title 31 U.S.C. Sec.5340-5355. Additionally, the Company and its staff understand that they must comply with the international Money Laundering Abatement and Financial Anti-Terrorism Act 2001, title III of the U.S.A. PATRIOT ACT of 2001, Public Law 107(“OFAC”) Rules and Executive Orders Blocking Property and Prohibiting Transactions with the Persons Who Commit, Threaten To Commit, or Support Terrorism, issued under the International Emergency Economic Powers Act.

It is the ethical and professional purpose of Monty Global Payments USA shareholders and directors to avoid that the facilities, financial products, and services of the Company be used to give legitimacy to funds that are, or will be, the product of illicit actions as defined by U.S. laws and regulations.

As MSB, Monty Global Payments USA is under Federal law, and must: (a) develop, administer and maintain a written Compliance Program; (b) designate a knowledgeable compliance officer to administer the compliance program; (c) institute an automated process to monitor all transactions; (d) provide training for required staff; and (e) conduct periodic, independent testing of the compliance program.

Furthermore, the Board of Directors of Monty Global Payments USA requires that said system includes specific written procedures for the compliance of the laws and regulations of the U.S. on money laundering and terrorist financing. Thus, it has assigned to the Compliance Officer the day-to-day responsibilities to ensure adequate compliance with documented procedures and has given the authority and appropriate level of autonomy to this senior officer to investigate and report on suspicious transactions. Also, internal policies and procedures include an appropriate training program for and training of personnel to increase the Company’s employees’ and directors’ awareness and knowledge in the area of money laundering and terrorist financing prevention and detection.

Monty Global Payments USA will file Suspicious Activity Reports (“SARs”) using the BSA E-Filing System at the FinCEN website, and file said report within 15 calendar days of the transaction. These policies and control procedures are set forth in our Procedures Manual, which is constantly updated.

Technology not only supports management of the business, but also provides efficient compliance with legal requirements and enables online access to all the necessary documentation. In addition to detecting fraud, it enables us to automatically detect money laundering transactions and issuers, triggering a robust system of alerts which are then subjected to detailed tracking and analysis by means of a second tier of analytic tools.
The Money Laundering Prevention Area is responsible for complying with all policies and procedures adopted by the entity in order to prevent money laundering, as well as analyzing any suspicious transaction detected and, where appropriate, notifying the Executive Service of the Commission for the Prevention of Money Laundering and Monetary Offences (SEPBLAC). The Money Laundering Prevention Area regularly reports its activities to company management.

The following are the main elements of the anti-money laundering and terrorist financing prevention policy:

Please contact us regarding any issue related to this page, or any other questions about money laundering prevention, at the following addresses: uac@mgpsa.com.