Date: June 16, 2025
Roogoo Inc. and its affiliated entities (collectively referred to as "Roogoo") are committed to participating in global initiatives to combat money laundering (ML) and terrorism financing (TF). Our commitment also includes ensuring strict compliance by all within the company with regulations related to anti-money laundering (AML), countering the financing of terrorism (CFT), and international sanctions. All relevant international laws, directives from related international organizations, and associated obligations form the core of our anti-money laundering charter.
The development of an anti-money laundering program is to ensure that Roogoo complies with applicable laws and regulations in the countries/regions where we conduct business operations. This includes establishing adequate risk and control mechanisms to mitigate any risks of money laundering or terrorism financing.
The components of our anti-money laundering program include the following elements:
Anti-Money Laundering / Countering the Financing of Terrorism Policy
The Anti-Money Laundering / Countering the Financing of Terrorism Policy sets forth the basic standards that Roogoo must adhere to. This includes:
a. Written policies, procedures, and internal controls to ensure compliance with applicable anti-money laundering laws and regulations
b. Appointment of a dedicated compliance officer (MLRO) responsible for the anti-money laundering program
c. Appointment of a dedicated compliance officer responsible for anti-money laundering operations and daily monitoring
d. Establishment of a robust governance framework to ensure oversight of the anti-money laundering program by senior management
e. High standards of "Know Your Customer" (KYC) principles, which extend beyond identifying and verifying all customers to include all associated parties, authorized representatives, beneficiaries (if applicable), and obtaining information on the purpose of customer accounts, sources of funds, and sources of wealth when necessary.
f. Risk assessment of customers based on customer type, industry, jurisdiction, and the products the customer intends to purchase or use
g. Enhanced due diligence for customers identified as higher risk, including politically exposed persons (PEPs), high-risk industries, those with adverse media, or customers with any other risk factors detected through our ongoing compliance monitoring (such as Know Your Transaction (KYT) or Transaction Monitoring (TM))
h. All unusual or suspicious customer activities will be documented internally and flagged in the system, and reported to external relevant regulatory authorities
i. Periodic review and update of customer KYC information based on the customer's risk rating
j. All employees must participate in annual anti-money laundering and countering terrorism financing training, and all new hires must complete the relevant training
k. Review and evaluation of the company's anti-money laundering program compliance by an independent audit firm
l. Continuous updates and retention of customer records in accordance with the timelines prescribed by relevant authorities
Prohibited Account Uses, Customers, and Business Types
a. Prohibited Business Relationships Roogoo shall not establish business relationships with the following customer types:
Individuals and entities listed on sanctions lists by U.S. authorities or international sanctions (e.g., United Nations Security Council, U.S. Office of Foreign Assets Control (OFAC), EU sanctions, Monetary Authority of Singapore lists, etc.);
Businesses and individuals suspected or confirmed to be involved in terrorism financing, criminal organizations, or supporting such organizations;
Shell banks with no physical presence in their place of registration
Customers registering transactions under fictitious names or aliases
Customers engaged in the manufacture, sale, or purchase of weapons or arms
Customers engaged in human trafficking
Customers engaged in human organ trading
Customers engaged in drug trafficking Customers engaged in illegal political contributions
b. Prohibited Asset Types Roogoo does not allow funds identified through Know Your Transaction (KYT) monitoring or KYC checks as proceeds of crime, used for terrorism financing, or belonging to criminal organizations, and prohibits establishing business relationships with such customers, even if the customers' criminal or illegal activities occur outside the jurisdiction.
c. Restricted Regions and Countries Roogoo shall not establish business relationships with customers from restricted regions and countries. This includes, but is not limited to, regions associated with sanctions, severe political instability, and/or economic inequality.
Roogoo's KYT
Roogoo strictly prohibits users from using our platform for illegal activities such as money laundering, terrorism financing, or illicit transactions.
Roogoo conducts real-time and ongoing Know Your Transaction (KYT) screening on all user transactions. If any suspected illegal transactions or behaviors are detected through KYT and transaction monitoring, Roogoo may take actions against the user, including but not limited to rejecting requests for fund inflows and outflows, issuing requests for relevant information, freezing accounts, and providing information to relevant regulatory authorities and reporting suspicious activities. Roogoo reserves all its rights under the contract with you and applicable laws.
Prohibited Activities
Roogoo wishes to remind users not to engage in the following behaviors on our platform, including but not limited to:
All transactions that may cause Roogoo to violate economic sanctions implemented or enforced by various government agencies, including but not limited to sanctions implemented or enforced by the U.S. Department of the Treasury's Office of Foreign Assets Control, U.S. Department of State, United Nations Security Council, EU member states, UK Treasury, Monetary Authority of Singapore, Hong Kong Monetary Authority, etc. Roogoo is committed to combating financial crime and complying with all applicable sanctions laws and regulations in the locations where we operate.
Transactions related to illegal activities, including but not limited to fraud, scams, fund theft, ransomware, malware, etc.
Transactions related to high-risk activities, such as mixing services, dark web markets.
Irregular, unusual, or rare transactions and deposits/withdrawals without logical business rationale, such as immediate withdrawals after deposits without any other investment or consumption activities in between.