Anti-Money Laundering (AML) Policy Statement

TX3 Funding is committed to the prevention and active deterrence of money laundering and the financing of terrorism. We take our responsibility to protect the integrity of financial markets seriously and maintain strict compliance with applicable AML regulations.

This AML Policy outlines the principles, procedures, and internal controls that TX3 Funding follows to detect, prevent, and report potential money laundering or terrorist financing activities in accordance with international best practices.

Policy Objectives

TX3 Funding’s AML Policy aims to:

  1. Establish clear and comprehensive guidelines to prevent money laundering and terrorist financing.
  2. Ensure compliance with all applicable AML and counter-terrorism financing laws and regulations.
  3. Promote awareness and understanding among all staff and partners of their AML responsibilities.
  4. Maintain transparent and ethical business practices at every operational level.

Definition of Money Laundering

Money laundering refers to the process of concealing or disguising the origins of illegally obtained money to make it appear as if it came from legitimate sources. This process typically includes one or more of the following activities:

  • Converting, transferring, or moving illicit proceeds to conceal their origin or to assist someone involved in generating such proceeds.
  • Concealing or disguising the true nature, source, location, disposition, movement, or ownership of illicit funds.
  • Acquiring, possessing, or using property with the knowledge that it originated from criminal activity.
  • Participating, assisting, or attempting to participate in any of the above acts.

TX3 Funding strictly prohibits any activity that may facilitate money laundering, directly or indirectly.

Stages of Money Laundering

Money laundering generally takes place in three stages:

  1. Placement – introducing illicit funds into the financial system.
  2. Layering – disguising the source of funds through complex transactions.
  3. Integration – reintroducing the laundered money into the economy as apparently legitimate funds.

Terrorist Financing

Terrorist financing involves the collection or provision of funds with the intention that they be used to carry out acts of terrorism. Unlike money laundering, the funds used for terrorism may originate from both legal and illegal sources.

  • Using legal business structures to fund or conceal terrorist activities.
  • Misusing charitable organizations for funding extremist operations.
  • Transferring money across borders to finance terrorism.

TX3 Funding implements rigorous controls to identify and prevent any transaction that may be connected to terrorist financing.

Applicable Laws and Regulations

Our AML framework aligns with globally recognized laws and standards, including but not limited to:

  • The Financial Action Task Force (FATF) Recommendations.
  • The USA PATRIOT Act and Bank Secrecy Act (BSA).
  • The European Union Anti-Money Laundering Directives (AMLD).
  • United Nations Security Council Resolutions related to counter-terrorism financing.

TX3 Funding continuously reviews these frameworks to ensure full compliance with international and local AML regulations.

Prohibited Activities

TX3 Funding strictly prohibits clients and employees from engaging in or facilitating any of the following activities:

  • Accepting funds derived from illegal activities.
  • Structuring transactions to evade reporting requirements.
  • Opening or maintaining anonymous or fictitious accounts.
  • Using third-party accounts or intermediaries to disguise the origin of funds.

Any violation of these prohibitions will result in immediate investigation and potential termination of the relationship.

Investigatory Cooperation

TX3 Funding fully cooperates with regulatory and law enforcement authorities by providing timely and accurate information as required under applicable AML laws.

Defenses and Legal Protection

Employees who report suspicious activities in good faith are protected by TX3 Funding’s whistleblower policy and relevant legal safeguards.

No disciplinary or legal action will be taken against employees who, acting in good faith, submit a suspicious activity report.

Transaction Monitoring

TX3 Funding continuously monitors customer activity to detect unusual or suspicious transactions. These include, but are not limited to:

  • Unusually large transactions inconsistent with a client’s typical behavior.
  • Frequent deposits or withdrawals without a clear legitimate purpose.
  • Transfers involving high-risk jurisdictions or offshore centers.
  • Structuring transactions to avoid reporting thresholds.

Detection and Prevention Measures

TX3 Funding has implemented robust systems and tools to identify suspicious activities and mitigate AML risks.

We apply both automated and manual review processes to flag irregular patterns, ensuring continuous vigilance.

  • Identity verification (Know Your Customer - KYC).
  • Risk-based transaction monitoring.
  • Screening against global sanctions and watchlists.
  • Ongoing review of client behavior and account activity.

Reporting Suspicious Activity

All employees are required to promptly report any suspected or confirmed cases of money laundering or terrorist financing to the Compliance Officer. Reports may include:

  • Description of the suspicious transaction or activity.
  • Identification details of the involved client(s).
  • Any supporting documentation or evidence.
  • Date, time, and method of detection.

Record Retention

TX3 Funding maintains complete and accurate records of client identification and transaction history to support investigations if necessary.

  • Customer identification documents.
  • Transaction records and communications.
  • Suspicious activity reports (SARs).
  • Internal compliance and training logs.

All records are securely stored and retained for a minimum of five (5) years, or longer when required by law.

Risk Assessment

TX3 Funding regularly evaluates its AML risk exposure to adapt its controls accordingly.

  • Assessing geographical risk factors.
  • Analyzing client profiles and transaction patterns.
  • Monitoring new products and delivery channels.
  • Reviewing third-party service providers and affiliates.

Our risk-based approach allows us to allocate resources efficiently while maintaining full regulatory compliance.

Sanctions Screening

TX3 Funding conducts comprehensive sanctions screening of clients, partners, and transactions against recognized international lists, including:

  • Office of Foreign Assets Control (OFAC).
  • European Union Sanctions List.
  • United Nations Security Council Sanctions List.
  • Her Majesty’s Treasury (HMT) Consolidated List.

Penalties for Non-Compliance

Failure to comply with this AML Policy may result in severe legal and disciplinary consequences, including:

  • Termination of employment or business relationships.
  • Administrative fines or civil penalties.
  • Criminal prosecution for willful violations.
  • Reputational damage to TX3 Funding and its partners.

TX3 Funding enforces a zero-tolerance policy for AML breaches.

Employee Obligations

All employees are personally responsible for adhering to AML requirements and must:

  • Complete AML training and certification programs.
  • Identify and verify customers in compliance with KYC procedures.
  • Report suspicious activities immediately.
  • Maintain confidentiality of all compliance-related information.

Shell Banks and Anonymous Accounts

TX3 Funding does not engage with shell banks or institutions that allow anonymous accounts.

  • We refuse to maintain correspondent relationships with shell banks.
  • We prohibit any transaction involving anonymous or fictitious accounts.
  • We require full transparency in all banking and payment operations.

Training and Awareness

TX3 Funding ensures that all employees are trained and aware of AML regulations and their responsibilities under this policy. Initial training covers AML fundamentals, red flags, and proper reporting channels. Employees learn to identify suspicious behavior, use internal reporting systems, and protect customer data. Ongoing refresher sessions reinforce best practices and regulatory updates through annual AML courses, scenario-based workshops, and new KYC rule briefings. TX3 Funding maintains full training records for auditing and compliance verification purposes.

Compliance Oversight

The Compliance Department monitors the implementation and enforcement of this AML Policy, ensuring all internal processes, systems, and third-party relationships meet AML standards. It conducts internal audits, updates AML procedures as laws evolve, reports to senior management, and liaises with regulators when necessary. Through continuous review and enforcement, TX3 Funding maintains transparent, effective, and compliant AML practices.