Lock Trust, Inc.
Anti-Money Laundering & Counter-Terrorist Financing Policy
Last updated: September 19, 2025
Purpose & Scope
This policy sets out the framework Lock Trust, inc., (“LockTrust,” “LT,” “we,” “our”) uses to prevent money laundering, terrorist financing, and other financial crimes.
It applies to all employees, contractors, officers, and representatives in every location where we operate or provide services to customers in the United States, United Kingdom, and European Union.
As a global financial institution, Lock Trust, Inc. is committed to full compliance with all applicable laws and regulations regarding Anti- Money Laundering (“AML”). Lock Trust’s policy is to prevent people engaged in financial crimes including money laundering, fraud, terrorist financing, and other financial crimes while utilizing any form of Lock Trust’s services.
Lock Trust has robust systems including policies and procedures to detect, prevent and report suspicious activity. To comply with OFAC (Office of Foreign Asset Control) requirements, and global sanctions, we screen our customer accounts against government watch lists. In addition, we may request that you provide us with documentation to help prove your identity or for business verification purposes. We report suspicious transactions to the financial intelligence unit in the respective country.
Regulatory Framework
LockTrust is committed to complying with:
- United States – Bank Secrecy Act (BSA), USA PATRIOT Act, FinCEN regulations, OFAC sanctions.
- United Kingdom – Money Laundering, Terrorist Financing & Transfer of Funds Regulations 2017, Proceeds of Crime Act 2002, Sanctions & Anti-Money Laundering Act 2018, FCA guidance.
- European Union – Anti-Money Laundering Directives (AMLD 4–6), EU Sanctions Regulations, GDPR (for data processing).
Where requirements differ, we apply the most stringent standard.
Risk-Based Approach
We assess and manage AML/CTF risks using a risk-based approach, considering:
- Customer type (individual, business, government, financial institution)
- Products and services offered
- Delivery channels (online, in-person, API)
- Geographic exposure (countries of residence, transaction destinations)
- Transaction size, volume, and patterns
High-risk relationships or transactions are subject to enhanced due diligence and approval by senior management.
Customer Due Diligence (CDD)
Before onboarding, we verify the identity of all customers and, where relevant, their beneficial owners.
CDD measures include:
- Collecting and validating government-issued ID or registration documents.
- Verifying addresses, source of funds, and purpose of account.
- Screening against sanctions, PEP (Politically Exposed Person), and adverse-media lists.
- Applying Enhanced Due Diligence (EDD) for high-risk or PEP customers.
Customer records are updated regularly, with periodic reviews based on risk.
Ongoing Monitoring
We continuously monitor accounts and transactions to identify:
- Unusual or complex activity
- Transactions inconsistent with a customer’s profile
- Activity linked to high-risk jurisdictions or sanctioned persons
Alerts are escalated to the Compliance Officer for review and potential filing of regulatory reports.
Recordkeeping
We retain CDD records, transaction data, and suspicious activity reports for at least 5 years (or longer where required by U.S., U.K., or E.U. law). Records must be retrievable promptly for regulatory or law-enforcement requests.
Reporting Obligations
- U.S.: File Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) with FinCEN as required.
- U.K.: Submit Suspicious Activity Reports to the U.K. Financial Intelligence Unit (UKFIU).
- E.U.: Report suspicious activity to the relevant Financial Intelligence Unit (FIU) in the Member State concerned.
Employees must escalate suspicious transactions to the Compliance Officer immediately.
Sanctions Compliance
We screen customers, counterparties, and transactions against:
- U.S. OFAC lists
- U.K. HM Treasury consolidated sanctions list
- E.U. consolidated financial sanctions list
- U.N. Security Council sanctions
Activity involving sanctioned parties is blocked or frozen, and reported where required.
Training & Awareness
All employees receive AML/CTF training at onboarding and annually thereafter. Training covers:
- Money laundering and terrorist financing risks
- Customer identification and verification
- Recognizing and escalating suspicious activity
- Recordkeeping and reporting duties
- Sanctions compliance
Specialized training is provided for staff in higher-risk roles.
Roles & Responsibilities
- Board of Directors – Approves this policy and oversees the AML/CTF framework.
- Compliance Officer / MLRO (Money Laundering Reporting Officer) – Manages implementation, reviews alerts, files reports, liaises with regulators.
- Employees & Contractors – Follow this policy, complete training, and promptly escalate concerns.
Independent Review
Our AML/CTF program is subject to periodic independent testing (internal audit or external consultant) to ensure effectiveness and regulatory compliance.
Breaches & Disciplinary Action
Violations of this policy or applicable AML laws may lead to disciplinary measures, up to and including termination of employment or contract, and may be reported to authorities.
Contact
Questions about this policy or suspicious activity should be directed to:
Compliance Officer (MLRO)
Lock Trust, Inc.
compliance@LockTrust.com