Pandora ANTI-MONEY LAUNDERING (AML) POLICY

1. Introduction

1.1 Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to establish guidelines to prevent, detect, and report potential money laundering and terrorist financing activities. This policy aligns with applicable laws and regulations and demonstrates Pandora Technologies's commitment to operating a compliant business.

1.2 Scope

This policy applies to all employees, contractors, agents, and any other individuals associated with Pandora Technologies, irrespective of the jurisdiction in which they operate.

1.3 Regulatory Framework

Pandora Technologies adheres to the anti-money laundering provisions outlined in the United States' Bank Secrecy Act (BSA), USA PATRIOT Act, Financial Action Task Force (FATF) recommendations, and any other applicable state and federal laws.

1.4 Definitions

• Money Laundering: The process of disguising the origins of illegally obtained money.
• Terrorist Financing: The act of providing funds for terrorist activities.
• Beneficial Owner: The natural person(s) who ultimately owns or controls an entity or asset.
• PEP: Politically Exposed Person, an individual who holds a public office and may present higher risks for potential involvement in money laundering.

2. Governance and Accountability

2.1 Roles and Responsibilities

The ultimate responsibility for the implementation of AML policies lies with the Board of Directors, with specific daily responsibilities assigned to the designated AML Compliance Officer and relevant business units.

2.2 Designated AML Officer

Pandora Technologies will appoint an AML Compliance Officer who will oversee AML policies, ensure compliance, report suspicious activities, and act as the primary liaison with regulators.

2.3 Board and Senior Management Involvement

Senior management and the Board are responsible for ensuring the effectiveness of Pandora Technologies’s AML framework by reviewing reports and audits, and by supporting resource allocation.

3. Risk-Based Approach

3.1 Risk Assessment

Pandora Technologies adopts a risk-based approach (RBA) to AML compliance, conducting regular assessments to identify and mitigate risks related to its customers, products, services, and geographic operations.

3.2 Customer Risk Categories

Customers are classified into different risk levels—low, medium, and high—based on factors such as geographic location, the nature of their business, and their financial activity.

3.3 Product, Service, and Geographic Risks

Certain products and services, or operations in specific jurisdictions, may present a higher risk for money laundering. The company will conduct enhanced due diligence in these areas.

4. Customer Due Diligence (CDD)

4.1 Customer Identification Program (CIP)

Pandora Technologies requires the verification of customer identities using reliable, independent source documents, data, or information before establishing any business relationship.

4.2 Enhanced Due Diligence (EDD)

For customers presenting higher risks, such as PEPs or customers from high-risk countries, enhanced measures will be taken to verify the source of funds and monitor their transactions.

4.3 Simplified Due Diligence (SDD)

For low-risk customers, simplified measures may be applied, in compliance with relevant regulatory allowances.

4.4 Ongoing Monitoring

Customer relationships are subject to ongoing monitoring to ensure that their transactions are consistent with the customer’s risk profile.

5. Transaction Monitoring and Reporting

5.1 Monitoring Transactions

Pandora Technologies employs automated transaction monitoring systems to detect unusual or suspicious activities. These systems use risk parameters to flag transactions for further investigation.

5.2 Suspicious Activity Reporting (SAR)

All suspicious transactions must be reported promptly through a Suspicious Activity Report (SAR) to the relevant authorities.

5.3 Currency Transaction Reporting (CTR)

For cash transactions exceeding regulatory limits, Pandora Technologies will file a Currency Transaction Report (CTR) in compliance with regulatory requirements.

5.4 Internal and External Escalation Procedures

Any unusual or suspicious transactions will be escalated internally for review by the AML Compliance Officer, who will determine if a SAR needs to be filed externally.

6. Record Keeping and Retention

6.1 Record Retention Policy

Pandora Technologies will retain records of customer identity, transaction history, and reports for a minimum period of five years, or as required by law.

6.2 Maintenance of AML Records

Records must be maintained in a manner that allows for prompt retrieval to respond to any regulatory or audit requests.

7. Employee Training and Awareness

7.1 Training Program

All employees must receive regular AML training to ensure they understand their responsibilities in preventing and detecting money laundering activities.

7.2 Ongoing Education

AML training programs will be updated regularly to reflect new threats, regulatory changes, and emerging best practices.

7.3 Employee Accountability

Employees who fail to comply with AML policies may face disciplinary action, including termination.

8. Internal Controls and Independent Audits

8.1 Internal Audits

Regular internal audits will be conducted to assess the effectiveness of Pandora Technologies's AML controls and processes.

8.2 External Audits

Independent third-party audits will be conducted as necessary to provide an objective review of the AML framework.

8.3 Audit Reports and Action Plans

Audit findings will be documented, and action plans will be implemented to address any identified deficiencies.

9. Sanctions and Regulatory Compliance

9.1 OFAC Compliance

Pandora Technologies will ensure compliance with the Office of Foreign Assets Control (OFAC) regulations and will not engage in transactions with sanctioned individuals or entities.

9.2 Other Applicable Sanctions Regimes

The company will also adhere to other international and domestic sanctions regimes applicable to its operations.

9.3 Penalties for Non-Compliance

Non-compliance with sanctions or AML regulations can lead to significant fines, penalties, and reputational damage.

10. Whistleblower and Reporting Mechanisms

10.1 Reporting Violations

Employees and external parties are encouraged to report any known or suspected violations of this AML policy through established channels.

10.2 Whistleblower Protection

Pandora Technologies ensures that individuals reporting violations in good faith are protected from retaliation.

11. Policy Review and Updates

11.1 Review Frequency

This policy will be reviewed annually, or as necessary, to ensure its effectiveness and compliance with applicable laws and regulations.

11.2 Amendment Procedures

The AML Compliance Officer will be responsible for recommending changes to this policy. Any amendments must be approved by the Board of Directors.

11.3 Approval by Board of Directors

The Board of Directors must approve this policy and any subsequent revisions to ensure it reflects the strategic objectives and regulatory requirements of Pandora Technologies

Approved By:
[April Hogan, Compliance Officer]
Date: 08-29-2024

This AML policy must be adhered to by all staff and stakeholders to ensure Pandora Technologies Inc’s compliance with anti-money laundering laws and regulations.