Trackwise LLC is committed to detecting and preventing money laundering, terrorist financing, sanctions evasion, and other financial crime. Trackwise is registered with FinCEN as a Money Services Business (MSB #31000299058422) and operates a written Anti-Money Laundering ("AML") / Bank Secrecy Act ("BSA") compliance program.
1. BSA / AML governance
- The program is owned by our designated BSA Officer / Chief Compliance Officer, who reports directly to senior management.
- Written policies and procedures are reviewed at least annually.
- An independent review of the program is conducted at least annually.
- All employees receive AML training appropriate to their role at hire and at least annually.
2. Risk-based approach
Trackwise applies a risk-based approach. We assess risk along customer type, geography, product, channel, and behavior dimensions, and apply proportionate controls.
3. Customer due diligence (CDD) and KYC / KYB
- Customer identity is verified through document, biometric, and database checks.
- For business customers, beneficial owners with 25% or greater ownership and one control person are identified and verified.
- Enhanced due diligence (EDD) is applied for high-risk customers, including PEPs and customers operating in high-risk geographies.
- We refresh customer information on a risk-based schedule.
4. Sanctions screening
We screen customers and counterparties at onboarding and on an ongoing basis against:
- OFAC SDN List and Consolidated Sanctions List
- UN consolidated sanctions list
- EU consolidated financial sanctions list
- UK HM Treasury sanctions list
- Country-specific lists where applicable
- PEP and adverse-media data
5. Transaction monitoring
Transactions are monitored using a combination of rule-based and behavioral analytics. Alerts are reviewed by trained analysts. The case management system maintains a full audit trail.
6. SAR / CTR reporting
Trackwise files Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) with FinCEN as required by 31 CFR Chapter X. We do not tip off subjects of SAR filings.
7. Recordkeeping
Trackwise retains BSA / AML records for at least five (5) years from the end of the customer relationship or the date of the relevant transaction, whichever is later.
8. Prohibited businesses and activities
See our Responsible Use Policy for the list of business types and activities for which Trackwise does not provide services.
9. Cooperation with law enforcement
Trackwise cooperates with U.S. and foreign law enforcement under applicable law. Lawful subpoenas, court orders, and 314(a) / 314(b) information-sharing requests should be directed to compliance@trackwise.finance.
10. Contact
compliance@trackwise.finance
Attn: BSA Officer, Trackwise LLC, 30 N. Gould St., Ste R, Sheridan, WY
82801, USA