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AML Policy

Initial release: January 2023 
Latest update: March 2 2024

Intro

ComiBlock Capital LLC and its subsidiary are committed to full compliance with all applicable laws and regulations regarding anti-money laundering procedures. ComiBlock Capital LLC and its subsidiary have adopted and will enforce the provisions outlined in Anti-Money Laundering Regulations, 2017 (‘AML Regulations) to prevent and detect money laundering, terrorist financing, and other illegal activities.

ComiBlock Capital LLC and its subsidiary, its personnel, and/or premises are inadvertently used for money laundering or other illegal activities, ComiBlock Capital LLC and its subsidiary can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee (each, an “employee”) is familiar with and complies with the policies and procedures outlined in this Compliance Manual.

This Compliance Statement is designed to assist all clients in adhering to ComiBlock Capital LLC and its subsidiary's policy and procedures, which, if followed diligently, are designed to protect themselves, ComiBlock ComiBlock Capital LLC, and its subsidiary, its employees, its facilities, and its activities from money laundering or other illegal activities.
 
To ensure that ComiBlock Capital LLC and its subsidiary policies and procedures are adhered to, ComiBlock Capital LLC and its subsidiary shall designate an Anti-Money Laundering Compliance Officer (the “Compliance Officer”).
 
The Compliance Officer is responsible for establishing and conducting employee training programs to ensure that all appropriate employees are aware of the applicable Anti-Money Laundering Regulations, ComiBlock Capital LLC, and its subsidiary's Anti-Money Laundering Policies and procedures and their responsibilities to these policies

→Objectives

Comply with all Anti-Money Laundering Rules and regulations of the jurisdictions it operates.

Require all employees to prevent, detect, and report to the Compliance Officer all potential instances in which ComiBlock Capital LLC and its subsidiary or its employees, its facilities, or its activities have been or are about to be used for money laundering, terrorist financing, and other illegal activity.

Provide for a Compliance Officer who shall ensure adherence to the ComiBlock Capital LLC and its subsidiary's Anti-Money Laundering Policies and Procedures.

Require all appropriate employees to attend anti-money laundering training sessions, so that all such employees are aware of their responsibilities under ComiBlock Capital LLC and its subsidiary's policies and procedures; this Compliance Manual; and as affected by current developments to anti-money laundering events.

 


→ WHAT IS MONEY LAUNDERING?

Money laundering involves the placement of illegally obtained money into legitimate financial systems so that monetary proceeds derived from criminal activity are transformed into funds with a legal source.

Money laundering has many destructive consequences, both for society as a whole and for those entities involved in money laundering activities. Concerning society as a whole, money laundering may provide resources for drug dealers, terrorists, and other criminals to operate and expand their criminal activities.

For entities, any involvement, whether to instigate, assist, conceal, or ignore the source, nature, location, ownership, or control of money laundering activities, can lead to both civil and criminal proceedings against both the individual and the entity involved. Additionally, the adverse effects, including the adverse publicity to the Firm, associated with involvement in money laundering events cannot be emphasized enough.

→ Money laundering transactions may include:

  1. Advising a potential or existing client on how to structure a transaction to avoid reporting and/or record-keeping requirements
  2. Engaging in any activity while willfully or recklessly disregarding the source of the funds or the nature of the Client's transaction;
  3. Engaging in any activity designed to hide the nature, location, source, ownership, or control of proceeds of criminal activity;
  4. Dealing with funds to facilitate criminal activity; or Dealing with the proceeds of criminal activity.