NatureTrak maintains internal controls, written policies, procedures and processes designed to ensure compliance with the reporting, monitoring, and record keeping requirements of the BSA and to detect potential money laundering.
The NatureTrak’s BSA/AML compliance program provides the following requirements:
• A system of internal controls to ensure ongoing compliance.
• Independent testing of BSA/AML compliance.
• An individual responsible for managing BSA compliance (BSA compliance officer).
• Training for appropriate personnel.
NatureTrak’s board of directors has designated a qualified individual to serve as the compliance officer. The compliance officer is responsible for coordinating and monitoring day-to-day BSA/AML compliance. The BSA compliance officer is also charged with managing all aspects of the BSA/AML compliance program and with managing NatureTrak’s adherence to the BSA and its implementing regulations; however, the board of directors is ultimately responsible for NatureTrak’s BSA/AML compliance.
A. Communicating changes in policy and procedures to affected personnel;
B. Monitoring daily red flags and AML Reports to identify any suspicious
C. Ensuring adequate training for all employees involved in cash transactions or wire transfers at NatureTrak. This training will be conducted at least annually for existing employees and at the time of hiring for all new employees;
D. Serving as a resource for BSA-related questions;
E. Retaining all documentation demonstrating compliance with the BSA for a period of not less than five years;
F. Monitor compliance with the Customer Identification Program as described below.
It is the Policy of NatureTrak to adopt and implement a written Customer Identification Program appropriate for its size and type of business as required by Section 326 of the USA PATRIOT Act and 31 CFR §103.121, the implementing regulations.
(1) collect and verify the identification information of any Customer seeking to establish a relationship with NatureTrak, to the extent reasonable and practicable;
(2) maintain records of the information used to verify the business or person’s identity, including name, address, date of birth, government issued id, and other identifying information;
(3) determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to NatureTrak by any government agency (i.e. control list or SDN List) and;
(4) provide adequate notification that NatureTrak is requesting information to verify customer identification.
NatureTrak employs a multi-faceted process that crosschecks Business owner identity and other artifacts against multiple public databases, which includes screening against the Office of Foreign Asset Control (OFAC). To perform the identity verification, business data elements are submitted to GIACT, a third-party identity authentication provider, in real-time.
Management has created the various reports below, which are provided to the bank daily to identify unusual/suspicious activity to help prevent anti-money laundering. These reports are provided to the bank on a daily/monthly basis to help the bank determine whether the activity is suspicious. Management will periodically evaluate the appropriateness of filtering criteria and thresholds used in the monitoring process.
The objective of CDD is to enable NatureTrak to predict with relative certainty the types of transactions in which a customer is likely to engage. NatureTrak’s CDD policies, procedures, and processes provide the critical framework that enables NatureTrak to comply with regulatory requirements and to report suspicious activity. These processes assist NatureTrak in determining when transactions are potentially suspicious.
We're pitching on stage! NatureTrak is proud to be a part of #M2020USA Startup Academy and we’re thrilled for the opportunity. Catch us in Las Vegas on October 27–30.
We were hosted on the Ganjapreneur podcast to discuss our origins and the current state of affairs in cannabis, compliance, and tech. Thanks to TG Branfalt for being a great host.