1. Purpose & Legal Framework
SeenLoop LLC maintains this Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy to prevent the use of our services for money laundering, terrorist financing, fraud, and other financial crimes. This policy applies to all transactions processed through SeenLoop's platform.
Legal Basis and Governing Frameworks:
- Bank Secrecy Act (BSA): The primary US federal law requiring financial institutions and certain businesses to maintain records and file reports that help detect and prevent money laundering.
- FinCEN Regulations: The Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury, issues regulations implementing the BSA. SeenLoop follows FinCEN guidance applicable to money services businesses and e-commerce operators.
- OFAC Compliance: The Office of Foreign Assets Control (OFAC) administers US economic sanctions programs. SeenLoop complies fully with all OFAC sanctions, including the Specially Designated Nationals (SDN) List restrictions.
- USA PATRIOT Act: Section 326 of the PATRIOT Act requires covered institutions to implement customer identification programs. SeenLoop applies these principles to high-value and high-risk transactions.
- Applicable Idaho State Law: SeenLoop is incorporated in Idaho and complies with applicable Idaho state financial crime statutes in addition to federal requirements.
SeenLoop is committed to full compliance with all applicable AML and counter-terrorism financing (CTF) requirements and maintains a risk-based approach to identifying, assessing, and mitigating financial crime risks.
2. Know Your Customer (KYC) Procedures
SeenLoop implements Know Your Customer procedures to verify the identity of clients and assess the risk associated with business relationships. KYC verification is applied to orders above $1,000 USD or to any order flagged as high-risk by our monitoring systems.
Required information for KYC verification:
- Legal Full Name: The full legal name of the individual placing the order (not a nickname or trade name).
- Valid Email Address: A verifiable email address that matches the registered account.
- Business Name and EIN: For business orders, the registered legal business name and Employer Identification Number (EIN) or equivalent tax identification number.
- Billing Address: A complete and verifiable billing address consistent with the payment method used.
- Payment Method Ownership Verification: Confirmation that the payment method used belongs to the client or their authorized business entity.
How we use KYC information:
- Risk Assessment: To evaluate the risk level associated with the client and the transaction, and to apply appropriate due diligence measures.
- Fraud Prevention: To verify that the transaction is legitimate and not associated with fraudulent activity, stolen payment methods, or identity theft.
- Legal Compliance: To fulfill our obligations under the BSA, OFAC regulations, and other applicable AML requirements, including maintaining required records.
KYC information is stored securely and retained for 5 years as required by applicable record-keeping regulations. It is not shared with third parties except as required by law or with Stripe for payment processing purposes.
3. Prohibited Clients & Jurisdictions
SeenLoop does not accept orders from, or provide services to, the following individuals, entities, or jurisdictions:
- OFAC Sanctioned Countries: We do not accept orders from clients located in, or primarily operating within, countries subject to comprehensive US sanctions, currently including: Iran, North Korea (DPRK), Cuba, Syria, and Russia (specifically the Crimea region and the so-called Donetsk and Luhansk People's Republics).
- OFAC Specially Designated Nationals (SDN) List: We do not provide services to any individual or entity named on the OFAC SDN list or other OFAC sanctions lists. We screen clients against these lists before accepting high-value orders.
- Shell Companies without Verifiable Purpose: We do not accept orders from shell companies or legal entities that cannot demonstrate a verifiable legitimate business purpose or whose beneficial ownership cannot be reasonably determined.
- Anonymous Clients for High-Value Orders: We do not accept anonymous or pseudonymous orders for transactions above $1,000. Identity verification is required for all high-value transactions.
- Previously Terminated Clients: We do not reinstate services to clients whose accounts were previously terminated due to fraud, AML violations, or violations of our Prohibited Items Policy.
SeenLoop screens new clients and high-value orders against OFAC databases, including the SDN list, as a standard part of our order acceptance process. Any match will result in immediate order rejection and account closure, and may be reported to OFAC as required.
4. Transaction Monitoring
SeenLoop monitors transactions on an ongoing basis to identify patterns or behaviors that may indicate money laundering, fraud, or other financial crimes. Our transaction monitoring program includes:
- Unusual Payment Patterns: Transactions that deviate significantly from a client's established order history or that do not match the profile of the client's stated business.
- Multiple Orders from Same IP with Different Payment Methods: A pattern of multiple orders placed from the same IP address using different payment methods may indicate the use of stolen card credentials or coordinated fraud.
- Orders with No Verifiable Business Purpose: High-value orders where the stated business purpose is vague, implausible, or inconsistent with the client's known business activities.
- Structuring: The practice of breaking large payments into multiple smaller amounts to avoid reporting thresholds — also known as "smurfing." Structuring is a federal crime under 31 U.S.C. § 5324 regardless of whether the underlying funds are from illegal activity.
- Payments from High-Risk Jurisdictions: Transactions originating from or funded by accounts in jurisdictions identified as high-risk for money laundering by FinCEN, the Financial Action Task Force (FATF), or other relevant authorities.
- Rapid Refund Requests: Requests for immediate refunds shortly after payment, which may indicate abuse of our refund process or payment reversal schemes.
5. Red Flags We Watch For
Our compliance team is trained to identify the following red flags that may indicate potential money laundering, terrorist financing, or financial fraud:
- Reluctance to Provide Identification: A client who is unwilling or unable to provide required identity verification information for a high-value or high-risk order.
- Payment Method Inconsistent with Stated Location: Use of payment methods, billing addresses, or IP addresses that are geographically inconsistent with the client's stated location or business jurisdiction.
- Unusual Urgency Combined with High-Value Order: Pressure to complete a large transaction immediately, particularly when combined with requests to waive standard verification procedures.
- Vague or Evasive Answers About Intended Use: Inability or unwillingness to clearly explain the intended purpose of the services being ordered, or answers that are inconsistent across communications.
- Requests to Use Cryptocurrency for Large Orders: Requests to accept payment in cryptocurrency rather than through our standard Stripe payment system, particularly for high-value orders, may indicate an attempt to obscure the source of funds.
- Third-Party Payments Where Payer Does Not Equal Beneficiary: Payment made by a third party on behalf of a client, where the relationship between payer and client cannot be satisfactorily explained or verified. This is a significant money laundering red flag.
- Round Number Transactions: Multiple transactions in exact round numbers (e.g., $999, $999, $999) that appear designed to stay below reporting thresholds.
- Complex or Unusual Payment Routing: Payments routed through multiple accounts, jurisdictions, or intermediaries without clear business justification.
6. Suspicious Activity Reporting
SeenLoop takes its Suspicious Activity Report (SAR) obligations seriously. When we have reason to suspect that a transaction involves money laundering, terrorist financing, structuring, or other financial crimes, we are required by law to take the following actions:
- File a Suspicious Activity Report (SAR) with FinCEN: SeenLoop is required to file a SAR with the Financial Crimes Enforcement Network (FinCEN) when we know, suspect, or have reason to suspect that a transaction involves funds from illegal activity, is designed to evade reporting requirements, lacks a lawful purpose, or involves the use of our services to facilitate criminal activity.
- Tipping-Off Prohibition: Under 31 U.S.C. § 5318(g)(2), SeenLoop is legally prohibited from notifying any person who is the subject of a SAR, or any person named in a SAR, that a SAR has been filed or is being considered. Violating this prohibition is a federal crime.
- Cooperation with Law Enforcement: SeenLoop cooperates fully with lawful investigations by federal and state law enforcement agencies. We respond promptly to subpoenas, court orders, and other lawful legal process.
- Order Freezing: We may freeze, delay, or cancel orders pending investigation when we have reasonable grounds to suspect financial crime. Clients will not be informed of the specific reason for delays in such cases.
7. Record Keeping Requirements
SeenLoop maintains comprehensive records of customer transactions and compliance activities in accordance with the Bank Secrecy Act and applicable FinCEN regulations:
- Customer Identification Records: KYC verification records, including identity documents and verification outcomes, are retained for a minimum of 5 years from the date the customer relationship ends.
- Transaction Records: Records of all transactions, including order details, payment amounts, dates, payment method information (as received from Stripe), and transaction status, are retained for a minimum of 5 years from the date of the transaction.
- SAR Filings and Related Documentation: Copies of all SAR filings, supporting documentation, and records of the decision-making process leading to SAR filings are retained for a minimum of 5 years from the date of filing.
- Communication Records: Relevant client communications related to high-risk transactions or compliance investigations are retained for a minimum of 5 years.
- Storage Security: All compliance records are maintained in encrypted storage with access restricted to authorized compliance personnel. Records are protected against unauthorized access, modification, and destruction.
Records are made available to authorized law enforcement and regulatory agencies upon receipt of lawful legal process.
8. Compliance Program
SeenLoop maintains a formal AML compliance program designed to meet the requirements of the Bank Secrecy Act and applicable FinCEN guidance. Our compliance program includes the following elements:
- Designated Compliance Officer: SeenLoop has designated a compliance officer responsible for developing, implementing, and overseeing the AML compliance program. The compliance officer has sufficient authority and resources to carry out their responsibilities effectively.
- Annual AML Training: All staff members who handle payments, onboard new clients, or process orders receive annual AML training covering: legal obligations, red flag recognition, SAR filing procedures, the tipping-off prohibition, and escalation procedures.
- Periodic Risk Assessments: SeenLoop conducts periodic risk assessments to identify and evaluate the money laundering and terrorist financing risks associated with our business model, client base, and geographic exposure.
- Regular Policy Reviews and Updates: This AML policy is reviewed at least annually and updated to reflect changes in applicable law, FinCEN guidance, OFAC sanctions programs, and evolving risk factors.
- Independent Testing of AML Controls: SeenLoop periodically tests the effectiveness of our AML controls through internal review or independent assessment to identify gaps and areas for improvement.
- Customer Due Diligence (CDD) Program: A risk-based CDD program governs the depth of verification applied to new and existing clients based on assessed risk factors.
9. Report Suspicious Activity
If you have information about suspected financial crime, money laundering, or terrorist financing involving SeenLoop's services, we encourage you to report it to our compliance team:
- Compliance Email: compliance@seenloop.com
- Subject Line: "AML/Compliance Report"
- General Contact: info@seenloop.com
All reports are taken seriously and investigated with strict confidentiality. Reporters acting in good faith are protected from retaliation under applicable whistleblower protection laws.
For Law Enforcement Agencies:
- Law Enforcement Inquiries: info@seenloop.com — Subject: "Law Enforcement Request"
- Emergency Requests: For urgent law enforcement requests involving imminent harm or active criminal investigations, include "URGENT" in the subject line.
- Legal Process: Subpoenas, court orders, and other legal process may be served via email to the addresses above or by mail to: SeenLoop LLC, Attn: Legal/Compliance, 1209 Mountain Road PL NE STE R, Albuquerque, NM 87110, USA.