Anti Money Laundering (AML) Policy (Revised April 2024)

AML Policy (Revised April 2024)

Introduction

Spring Development Bank is committed to preventing the use of its services for money laundering and terrorism financing. The following Anti-Money Laundering policy and procedures are designed to comply with the regulatory requirements and obligations set out by the interim government, NUG.

Policy Statement

Spring Development Bank shall conduct its business in accordance with the principles of the Anti-Money Laundering (AML) regulations and shall take proactive steps to detect, prevent, and report activities that may involve money laundering or terrorism financing.

AML Procedures

1. Deposits holding period requirement

• Parameters: 30 days holding period requirement applies to fixed deposits and all currencies (SGD, THB, AUD, EUR, GBP, MYR, JPY, KRW, USD) except MMK. (Gold deposits subject to review).
• Restriction: Aforementioned deposits with holding period less than 30 days are subject to the following AML Rules 2 to 4 with Exceptions set out under Rule 5.

2. Weekly USD/USDT withdrawal limit

• Parameters: Withdrawal requests above $5,000 within a single week.
• Restriction: Withdrawal requests above $5,000 in a single lump sum transaction or various smaller requests made up to such amount with less than 30 days holding period will be rejected.
• Exceptions:

1. Transactions involving MMK to USD exchanges are excluded.
2. Transactions involving USDT deposits and withdrawals are exempt, except in cases where the withdrawal exceeds 10,000 USDT (weekly), which should be escalated to the AML team for review.

3. Daily USD/USDT withdraw limit

• Parameters: Withdrawal requests above $1,000 in a single day.
• Restriction: Withdrawal requests above $1,000 in a single lump sum transaction or various smaller requests made up to such amount with less than 30 days holding period will be rejected.
• Exceptions:

1. Transactions involving MMK to USD exchanges are excluded.
2. Transactions involving USDT deposits and withdrawals are exempt in aligned with Rule 2B above.

4. USD deposits and USDT withdrawals limit

• Parameters: Patterns of USD deposits followed by USDT withdrawal.
• Rejection: A single withdrawal request above 500 USDT.
• Exception:

1. Transactions involving MMK to USD exchanges are excluded.
2. Transactions involving USDT deposits and withdrawals are exempt in aligned with Rule 2B above.

5. Exceptions to Rules 1 to 4

1. Withdrawal requests via Bond cashed in (up to two users, i.e Bond cashed in from RM to user A, user A then transferred to user B, user B then request withdrawal). Any withdrawal requests beyond this chain will be subject to review. Settlement team to share the details in USDT space.
2. Nway Oo Hti winnings in MMK currency are not subjected to AML. Note: this exception only applies to winnings in MMK currency.
3. Priority banking
4. MOD withdrawal up to $10,000 USDT. (check the email address org. format)
5. USD swap from GOLD requires AML review.
6. Any currencies and/or fixed deposits holding period more than 30 days. (see Rule 1)
7. Any withdrawal request of USDT for the same/or less value of USDT deposit within 24 hours.
8. Any discretionary base transactions (i.e urgent request for the on-ground requirements or emergency aids) that are verified by trusted source.

*** Please note that AML officers will coordinate with the legal department to conduct a thorough examination of any policy violations. They will also communicate directly with the affected customers to clarify the reasons for any transaction rejections and inform them about the duration of any imposed restrictions.

Compliance and Reporting

SDB will maintain and regularly update systems and controls to ensure compliance with AML regulations. This includes training staff, conducting regular audits, and reporting suspicious activities to the relevant authorities.

Review and Amendments

This policy and its procedures will be reviewed annually to ensure relevance and compliance with current laws and regulations. Amendments will be made as necessary to reflect changes in legislation or bank operations.

Conclusion

Spring Development Bank's AML policy and procedures reflect our commitment to upholding the highest standards of compliance and integrity. By adhering to these guidelines, we protect our customers, our Relationship Managers, Agens, our bank, and the digital financial system from being exploited for money laundering and terrorism financing.

Contact us

AML Officers can be contacted at [email protected] for any questions in relation to account restrictions, rejections, or transactions rectification process.