Anti-Money Laundering (AML) Policy
Introduction
As a company, SysAid is committed to conducting its business in accordance with the highest
ethical, moral and legal standards. This includes, but is not limited to complying with all
applicable laws and regulations focused on combatting money laundering, terrorist financing or
other illicit activity. This policy has been developed to reduce the risk of money laundering as
may be connected with the sale of our products and services. This policy recognizes the need
for awareness by SysAid to comply with such laws and regulations wherever SysAid operates
and within the jurisdictions to which it sells its products and services. Any employee who
violates this Policy or permits, assists or encourages anyone to violate the Policy may be
subject to appropriate disciplinary action, up to and including dismissal, and may be subject to
personal civil or criminal fines.
Policy Statement
It is SysAid’s policy to comply with all applicable AML Laws in all lines of our business, and to
this end, SysAid only conducts business with customers and vendors involved in legitimate
business activities whose funds are derived from legitimate sources. Money laundering means
exchanging money that was obtained criminally for money or other assets that are ‘clean’, ie,
without an apparent connection to criminal activity. Money laundering includes money used to
fund terrorism or other illicit activity. To that end, SysAid shall not engage in any activity
considered to be money laundering such as (1) conducting a transaction involving criminal
property, (2) the conversion or transfer of money or goods, knowing or suspecting that such
money or goods was derived from criminal activity for the purpose of concealing the illicit origin
of said money or goods or assisting any person in same, (3) acquisition or use of criminal
property, (4) promoting or maintaining any unlawful activity, or (5) participation in, attempting to,
facilitating, encouraging, or counseling any of the above. Such a broad policy stands for the
proposition that anyone could be in violation upon becoming aware or suspicious of criminal
property within the business without reporting such concern. To that end, it is each employee’s
duty under this Policy to understand his/her obligations hereunder and report any suspicious
transaction to his/her supervisor or other member of management.
No employee shall be criticized for any loss of business resulting from adherence to this Policy,
nor will an employee be penalized or otherwise suffer a consequence by alerting senior
management or the board of a known or suspected breach of this Policy. This Policy has been
approved by SysAid’s Chief Executive Officer who shall remain this Policy’s final authority.
