Anti-Money Laundering (Aml) And Know Your Customer (Kyc) Policy
Effective Date: January, 1, 2026
Purpose and Regulatory Context
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes the internal controls, review procedures, and documentation standards used by Afintrix Advisory Analytics LLC (“Afintrix,” “we,” “us,” or “our”) to identify, assess, and manage risks related to money laundering, terrorist financing, fraud, tax evasion, and other financial misconduct.
Afintrix is an advisory, analytics, and governance firm providing structured oversight, compliance, and financial analysis support. The firm does not accept or hold client funds, execute transactions, or provide financial custody.
This policy is designed to align with applicable expectations under the Bank Secrecy Act (BSA), USA PATRIOT Act, regulations administered by the U.S. Department of the Treasury, Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and other applicable federal and state authorities, to the extent relevant to Afintrix’s role.
Policy Objectives
The objectives of this policy are to ensure that Afintrix:
- Maintains a documented, risk-based approach to identifying and assessing financial crime exposure
- Verifies the identity and legitimacy of clients and counterparties prior to engagement
- Applies consistent screening and review procedures across all engagements.
- Identifies and escalates potentially suspicious or high-risk activity encountered during oversight, analytical, or compliance work
- Maintains complete, accurate, and retrievable records supporting AML and KYC determinations
- Cooperates with lawful regulatory inquiries when required by applicable law
Scope of Application
This policy applies to:
- All Afintrix personnel, including employees, contractors, and authorized representatives.
- All clients, counterparties, and entities subject to onboarding or engagement review.
- All service areas provided by Afintrix, including but not limited to:
- Tax Services
- Accounting and Bookkeeping
- Payroll Services
- Regulatory Compliance, Risk, and Advisory Support
- Financial Planning and Performance Reporting
- Asset and Depreciation Tracking
- Compliance Education and Training
- Fraud Forensics
- Suspicious Activity Monitoring
- Transaction Analytics
- Financial Data Archiving
- Business Entity Formation and Setup
This policy governs AML – and KYC – related activities conducted in connection with these services.
Risk-Based Approach
Afintrix applies a documented risk-based approach to AML and KYC oversight. Risk assessments consider factors including, but not limited to:
- Client ownership and control structure
- Jurisdictional exposure
- Nature and purpose of the engagement
- Types of financial data reviewed
- Transactional complexity or unusual activity indicators
- Prior compliance, regulatory, or enforcement history, where known
Clients and engagements are categorized according to assessed risk level. Enhanced review measures are applied when elevated risk is identified.
Know Your Customer (KYC)
Before initiating an engagement, Afintrix collects and reviews information sufficient to establish client identity and legitimacy. KYC procedures may include:
- Legal name, formation documents, and registration status
- Government-issued identification for individuals
- Tax identification numbers (EIN, SSN, or equivalent)
- Beneficial ownership and control information
- Description of business activities and engagement purpose
Information is reviewed for completeness, internal consistency, and reasonableness relative to the engagement scope.
Ongoing Monitoring
During engagements, Afintrix monitors information encountered through analytical review, compliance assessment, or oversight activities for indicators of potential financial crime, including:
- Inconsistent or unexplained transaction patterns
- Unsupported adjustments or documentation gaps
- Indicators of misrepresentation or concealment
- Activity involving sanctioned jurisdictions or entities
Monitoring is limited to information available within the defined engagement scope and does not constitute continuous transaction surveillance.
Suspicious Activity Escalation
When potentially suspicious activity is identified, Afintrix documents observations and escalates concerns internally for review. Actions may include:
- Additional analytical review
- Requests for clarification or supporting documentation
- Limitation, suspension, or termination of the engagement
- Consultation with legal counsel
Afintrix does not file Suspicious Activity Reports (SARs) unless legally required based on its role and applicable regulations.
Recordkeeping
AML and KYC records are maintained in a secure manner and retained in accordance with applicable regulatory expectations and the firm’s Record Retention and Document Management Policy.
Training and Awareness
Personnel receive periodic training appropriate to their role on AML and KYC principles, risk indicators, escalation procedures, and documentation requirements relevant to Afintrix’s oversight and analytical activities.
Policy Review and Updates
This policy is reviewed periodically and updated as necessary to reflect changes in regulatory expectations, risk exposure, or firm operations.
