(AML) ANTI MONEY LAUNDERING AND ANTI-TERRORIST FINANCING POLICY STATEMENT
InfoUSA and its subsidiaries, EasyTel.Net, Genie Bancor.Com, Dialtel and Universal Office Corporation, (hereinafter collectively "IUSA") recognize that The International Money Laundering Abatement and Anti-Terrorist Financing Act of 2001 ("Act") imposes important new obligations on all financial service firms for the detection, deterrence and reporting of money laundering activities. Under the Act, money laundering is defined as any financial transaction using income derived from criminal activity including, but not limited to, drug trafficking, fraud, illegal gambling and terrorism. IUSA has established the following policies to ensure thorough compliance with all laws and regulations regarding money laundering and anti-terrorist financing.
Prior to the opening of any new account, which conducts over an aggregate amount of one thousand dollars, per day, in monetary transactions, IUSA shall document the identity, nature of business, income, source of assets, and the objectives of each such prospective customer. Accounts for persons or entities from countries that do not cooperate with the Financial Action Task Force (FATF) guidelines on money laundering and anti-terrorist financing shall be subject to a heightened level of scrutiny. Accounts in the name of, or related to, any person or entity on the Office of Foreign Asset Control (OFAC) Specially Designated Nationals and Blocked Person list will not be accepted.
On an ongoing basis, IUSA shall review account activity for evidence of suspicious transactions that may be indicative of money laundering activities. This review may include surveillance of: 1) money flows into and out of accounts, 2) the origin and destination of wire transfers, 3) non-economic transactions, and 4) other activity outside the normal course of business.
Every officer and employee of IUSA shall be responsible for assisting in the firm's efforts to uncover and report any activity that might constitute, indicate or raise suspicions of money laundering and/or terrorist financing. To this end, IUSA shall provide continuing education and training of all such persons.
Should any officer, employee of IUSA have any knowledge, suspicions or information regarding any potential of the above activities, that individual shall immediately notify IUSA's Security Department. IUSA's Security Officer shall document the reported activity, investigate fully, and, if warranted, report such activity to the senior management of IUSA.
IUSA shall comply with all trade and economic sanctions imposed by OFAC against targeted foreign countries and shall cooperate fully with government agencies, self-regulatory organizations and law enforcement officials regarding these matters.
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