Last updated January 29, 2025.

1. Introduction

Trend Flow Studio (“The Company”) is committed to conducting its business in accordance with the highest ethical standards and complying with all applicable laws and regulations, including those related to Anti-Money Laundering (AML). This AML policy describes the measures and procedures designed to prevent, detect and report money laundering and other illegal financial activities.

2. Scope

This policy applies to all Trend Flow Studio employees, contractors, consultants and partners. It covers all activities, transactions and relationships conducted on behalf of the Company.

3. Regulatory Framework

Trend Flow Studio complies with all relevant AML laws and regulations in the jurisdictions in which it operates, including, but not limited to: 

• Financial Action Task Force (FATF) Recommendations 
• Local AML laws in the Company's regions of operation 

4. Objectives

The objectives of this AML policy are: 

• Prevent the use of the Company's services for money laundering or terrorist financing.
• Establish robust systems for monitoring, detecting and reporting suspicious activities.
• Ensure that all personnel are adequately trained in AML practices.

5. Key Principles

Know Your Customer (KYC): 

• The Company implements rigorous KYC procedures to verify the identity of customers, partners and stakeholders. 
• Required documentation includes government-issued identification, proof of address and, where applicable, verification of source of funds. 

Risk-Based Approach: 

• Risk assessments are conducted to identify and mitigate money laundering risks. 
• Customers and transactions are categorized according to risk levels (low, medium or high). 

Transaction Monitoring: 

• Transactions are continuously monitored to identify unusual or suspicious patterns. 
• Increased scrutiny is applied to high-risk customers and transactions. 

Record Keeping: 

• Records of all customer identification documents, transaction data and AML activities are retained for at least five years or as required by applicable laws. 

6. Suspicious Activity Report

Employees are required to report any suspicious activity to the AML Compliance Officer (AMLCO) designated by the Company. The AMLCO is responsible for: 

Investigate suspicious activity reports. 

File Suspicious Activity Reports (SARs) with the corresponding regulatory authorities. 

7. Training and Awareness

Regular training programs are conducted for all employees to ensure knowledge of AML laws and internal procedures. 

Training includes recognition of suspicious activities, reporting mechanisms and the importance of compliance. 

8. Compliance and Audit

The Company conducts regular audits of its AML program to ensure its effectiveness and compliance with applicable laws. 

Independent reviews may be conducted periodically to evaluate the AML framework. 

9. Penalties for Non-Compliance

Failure to comply with this policy or applicable AML regulations may result in disciplinary action, including termination of employment or association, and could expose both the individual and the Company to legal and financial penalties. 

10. Review and Upgrades

This AML policy is reviewed annually or as necessary to reflect changes in applicable laws, regulations or business operations. 

11. Contact Information

For questions or concerns regarding this AML policy, please contact the AML Compliance Officer at [email protected]. 

12. Approval

This AML policy has been approved by Trend Flow Studio management and is effective January 15, 2025.