Rideaway

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Rideaway Anti-Money Laundering (AML) & Counter Terrorism Financing (CTF) Policy

  1. Policy Statement

Rideaway takes a zero-tolerance approach to money laundering, terrorism financing, and all illicit activities. We are committed to complying with relevant legislation and international standards, ensuring that our platform is not used to facilitate criminal activity. This policy outlines our approach to managing risks associated with AML and CTF and provides guidance to our global network of sellers and buyers.

  1. AML & CTF Legislative Framework

Our global operations aim to adhere to a variety of legislative frameworks, ensuring compliance with the most recent AML/CTF regulations, including:

  • Money Laundering Regulations 2017 (as amended by MLR 2019) and Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020: Following Brexit, the 2020 amendment sets out UK-specific provisions for AML/CTF, particularly in cross-border transactions.
  • Proceeds of Crime Act 2002 (POCA): POCA remains the cornerstone legislation for the confiscation of proceeds from crime in the UK.
  • Terrorism Act 2000 (TACT): Updated by the Counter-Terrorism and Border Security Act 2019, which strengthens measures for combatting terrorism financing.
  • Sanctions and Anti-Money Laundering Act 2018 (SAMLA): Provides the UK government with powers to impose sanctions and address global money laundering and terrorism financing threats.
  • International Frameworks: We also adhere to Financial Action Task Force (FATF) standards, ensuring compliance with global AML/CTF guidelines, as well as the 6th EU Anti-Money Laundering Directive (6AMLD) for transactions involving EU-based users.
  1. Key Responsibilities

All Rideaway employees, partners, sellers, and buyers are obligated to:

  • Conduct customer due diligence (CDD) and know-your-customer (KYC) checks on users of the platform.
  • Monitor transactions for suspicious activities, especially where there are cross-border or high-risk transactions.
  • Report any suspicious activities to the designated Money Laundering Reporting Officer (MLRO) in line with internal Suspicious Activity Reporting (SAR) procedures.
  • Refrain from “tipping off” users about ongoing investigations or SARs.
  • Cooperate fully with law enforcement agencies and comply with sanctions lists, especially where transactions involve politically exposed persons (PEPs) or sanctioned entities.
  1. Risk-Based Assessment

We apply a risk-based approach to AML and CTF compliance, considering:

  • Global Nature of Transactions: Sellers and buyers from various countries, including those with higher risk profiles.
  • Transaction Patterns: High turnover or one-off transactions that may signal illicit activity.
  • Geographical Considerations: Transactions involving jurisdictions known for high levels of corruption or limited AML regulations will require enhanced due diligence.
  • Non-Face-to-Face Interactions: All remote transactions will be subject to additional checks to mitigate identity fraud and other risks.
  1. Customer Due Diligence (CDD) and Know-Your-Customer (KYC)

Rideaway requires the following from its users:

  • Identity Verification: All sellers and buyers must provide acceptable identification documents during registration.
  • Enhanced Due Diligence (EDD): This applies to higher-risk clients, including international transactions from non-regulated or high-risk jurisdictions, PEPs, or transactions exceeding a certain value.
  • Ongoing Monitoring: Transactional behavior will be monitored continuously for red flags, such as unusually large cash payments or rapid movement of funds across borders.
  1. Politically Exposed Persons (PEPs)

Enhanced due diligence will apply to users identified as PEPs, their family members, or known associates. The Rideaway platform will use electronic verification tools to screen users against PEP lists and ensure compliance with international sanctions.

  1. MLRO Responsibilities & Suspicious Activity Reporting (SAR)

The MLRO for Rideaway is responsible for:

  • Monitoring unusual or high-risk transactions.
  • Reviewing internal SARs and deciding whether to escalate them to law enforcement.
  • Ensuring all employees and partners are trained in AML and CTF procedures.
  1. AML Record Keeping

We maintain records of all AML and CDD-related activities for a minimum of five years after the transaction or relationship ends, including:

  • Client identification documents
  • Records of suspicious activity reports
  • Training records for staff.
  1. AML Training

All Rideaway staff will receive regular training on:

  • Risk factors for money laundering and terrorism financing
  • Procedures for identifying and reporting suspicious activities
  • Updates on emerging threats and regulatory changes in the AML/CTF landscape.
  1. Compliance and Sanctions

Failure to adhere to these policies may result in the suspension or removal of user accounts from the Rideaway platform, internal disciplinary action, and potential criminal prosecution.

Please contact justin@rideaway.io with any concerns or inquiries.