Rain Management WLL (collectively, with its branches and subsidiaries, the “Company”) has implemented this Anti-Money Laundering Policy and Associated Procedures (collectively, the “AML Policy”) to prevent money laundering and terrorist financing in relation to its business. We require all of our directors, officers, employees, contractors, and agents (collectively, “Representatives”) to read, understand, and follow this AML Policy in the course of performing services for the Company. We also expect our vendors and other business partners (collectively, “Business Partners”) to adopt and follow appropriate risk-based compliance standards to prevent money laundering and the financing of terrorism in relation to the services that they perform for us. This is a summary of our AML program and policy. Please forward any queries to firstname.lastname@example.org.
The Company prohibits all Representatives and Business Partners from engaging in money laundering and/or terrorist financing in relation to the Company’s business. The Company and its Representatives and Business Partners in the course of performing services for the Company must comply with all anti-money laundering (“AML”) and combating the financing of terrorism (“CFT”) laws and regulations applicable to the Company’s business anywhere in the world.
In an effort to ensure compliance with applicable AML/CFT standards, the Company has implemented the following “four pillars”: (i) the development of internal policies, procedures, and controls; (ii) the designation of an MLRO; (iii) an ongoing employee training program; and (iv) an independent audit function to test the compliance program. The Company has also established implemented a written customer identification program (“CIP”) (also referred to as “know-your-client” or “KYC” program) set forth in this AML Policy to understand our customers/account holders and their source of funding.
The Company is based in Manama, Bahrain where it operates a digital currency exchange licensed by the Central Bank of Bahrain (“CBB”). The Company is committed to complying with applicable AML/CFT laws and regulations of Bahrain consistent with its obligations under its CBB license. All Representatives and Business Partners must understand that compliance with applicable Bahraini AML/CFT laws and regulations is critical so that the Company can continue to maintain its CBB license. This includes, but is not limited to:
In addition, certain principals of the Company are from the United States. In their personal capacity, those principals remain subject to U.S. AML/CFT laws and regulations irrespective of where they are located. At this stage, the Company is not engaged in any business in the United States, nor does it maintain or intend to allow U.S. customers/clients/users to gain access to its digital currency exchange or related products or services. Should you learn of any activities that contradict this Company position, you must notify the MLRO so that he or she can determine whether any registration, reporting, record keeping, and/or other AML/CFT compliance program requirements will apply to the Company under U.S. state or federal laws and regulations in addition to those that are already contained in this AML Policy.
Our MLRO/CCO is responsible for developing and enforcing the policies and procedures of our AML Program. Our MLRO/CCO is required to report any violations of our AML Program directly to our CEO and our Board. In addition, our MLRO/CCO is responsible for recording and filing SARs, CTRs and performing a AML Program audit at least annually.
We file SARs if we know, suspect or have reason to suspect suspicious activities have occurred on Rain. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. Our MLRO/CCO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR.
Our MLRO/CCO maintains records and supporting documentation of all SARs and CTRs that have been filed.
Effective “customer due diligence” or “know-your customer” or “KYC” measures are essential to the management of AML/CFT risk. Proper due diligence is also relevant in the context of the Company’s relationships with certain third party vendors. Rain has the right but is not limited to obtaining the following while opening a personal account:
If the Diligence Subject is a legal entity or a legal arrangement such as a company or trust, the MLRO must obtain and record the following information from original identification documents, databases, or websites, in hard copy or electronic form, to verify the Diligence Subject’s legal existence and structure:
Enhanced CDD measures beyond the usual process of identification and verification are required for Diligence Subjects that present a higher risk with regard to AML/CFT concerns. This process is available at the MLRO/CCO’s discretion.
Because of the importance of this policy and the procedures set forth herein, the MLRO shall establish and implement an employee training program. The purpose of the training program shall be to familiarize relevant employees of the Company with the Company’s specific AML/CFT procedures and provide instruction for recognition of suspicious activities. In addition, the MLRO will ensure that employees are trained on the obligation to report suspicious transactions to the MLRO. All relevant employees and new hires must participate in the training. The MLRO is responsible for providing updated training to employees as necessary.
The MLRO shall ensure that independent and effective audits the Company’s AML/CFT compliance program occurs on an annual basis. The MLRO, in consultation with the Compliance Officer, shall appoint a qualified and objective third party to conduct this audit.
All audits must involve appropriate testing of an appropriate sample of Company transactions as determined by the auditor. All AML/CFT audit reports must be shared with the Company’s MLRO, Compliance Officer, internal legal counsel (if any), and the Governing Body. The MLRO must brief the Company’s Governing Body on corrective actions (if any) that the Company will take to address any deficiencies revealed in an audit report.
The Company shall keep and maintain internal records pertaining to the identity of each Business Partner, CDD, internal and external STRs, employee training, and compliance audits for at least five (5) years or such other period as may be required by applicable law. In addition, the Company is committed to maintaining accurate books, records, and accounts in relation to its business. Further guidance regarding the maintenance of these accounting standards appears in our Code of Conduct and Anti-Bribery Policy.