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AML / BSA Policy Statement

Effective date: [launch date] · Last updated: [launch date]

1. Cloud Excel's commitment

Cloud Excel LLC ("Cloud Excel") is committed to full compliance with the laws and regulations applicable to anti-money laundering, counter-terrorism financing and economic sanctions. As a Money Services Business registered with the Financial Crimes Enforcement Network (FinCEN) and licensed by the Florida Office of Financial Regulation, we operate under the framework of:

  • Bank Secrecy Act (BSA) — 31 U.S.C. §§ 5311 et seq.
  • USA PATRIOT Act
  • 31 CFR Part 1010 and Part 1022 (implementing regulations for MSBs)
  • Office of Foreign Assets Control (OFAC) — 31 CFR Parts 501–598
  • Anti-Money Laundering Act of 2020 (AMLA) and Corporate Transparency Act (CTA)
  • Chapter 560 of the Florida Statutes and Rule 69V-560, F.A.C.
  • Foreign Corrupt Practices Act (FCPA) — 15 U.S.C. §§ 78dd-1 et seq.
  • Guidance of the Financial Action Task Force (FATF)

2. Formal BSA/AML program

Cloud Excel maintains a formal, documented Anti-Money Laundering program ("AML Program") in compliance with 31 CFR § 1022.210, comprising the four mandatory pillars and reinforced by the fifth pillar required by the AMLA (Customer Due Diligence beneficial ownership):

  1. Policies, procedures and internal controls, formally documented
  2. Designated AML Compliance Officer
  3. Ongoing training of directors, employees and providers with access to client data
  4. Independent testing of the program by a qualified external auditor
  5. Customer Due Diligence and Beneficial Ownership per 31 CFR § 1010.230

3. Customer Identification Program (CIP)

Before establishing any commercial relationship, Cloud Excel conducts a rigorous Customer Identification Program ("CIP"), based on:

  • Verification of the identity of the corporate client
  • Verification of beneficial owners with ≥25% ownership and the person exercising significant control over the entity
  • Corporate, tax and operational documentation
  • Verification of address and economic activity
  • Initial screening against sanctions and PEP lists

4. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

Cloud Excel adopts a risk-based approach to due diligence:

4.1 Standard CDD

  • Understanding of the nature and purpose of the relationship
  • Assessment of the expected transaction pattern
  • Ongoing monitoring
  • Periodic updating of information

4.2 Enhanced Due Diligence (EDD)

We apply enhanced EDD in higher-risk situations, per 31 CFR § 1010.610 and FinCEN and FATF guidance:

  • Transactions involving higher-risk AML/CFT jurisdictions
  • Politically Exposed Persons (PEPs), their immediate family and known close associates
  • Cross-border corridors under heightened regulatory scrutiny
  • High-volume or unusually complex transactions
  • Clients serving third parties in legitimate commercial activity

EDD may include additional verification of source of funds and source of wealth, senior compliance officer approval, enhanced monitoring and more frequent periodic reviews.

5. Sanctions compliance (OFAC)

Cloud Excel maintains a formal compliance program for sanctions administered by the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC), aligned with the 2019 Framework for OFAC Compliance Commitments:

  • Ongoing screening against the SDN List, Sectoral Sanctions Identifications (SSI) List, Non-SDN Menu-Based Sanctions List, Foreign Sanctions Evaders List and other applicable OFAC lists
  • Application of the 50% Rule for beneficial ownership aggregation
  • Screening against UN, EU, UK and other relevant jurisdictions' lists
  • Blocking or rejection of transactions as required by law
  • Mandatory reporting of blocks to OFAC within 10 days
  • Record retention for at least 5 years

5.1 Comprehensively sanctioned jurisdictions

Cloud Excel does not accept or process payments involving:

  • Cuba (31 CFR Part 515)
  • Iran (31 CFR Parts 560, 561)
  • North Korea (DPRK) (31 CFR Part 510)
  • Syria
  • The Crimea, Donetsk, Luhansk, Kherson and Zaporizhzhia regions of Ukraine (E.O. 14065, 31 CFR § 589.201)

Transactions involving the Russian Federation, Belarus, Venezuela or Myanmar are subject to additional restrictions and may be declined at the discretion of the compliance officer.

6. Travel Rule

Cloud Excel complies with the BSA Travel Rule (31 CFR § 1010.410(f)), transmitting or collecting required originator and beneficiary information on qualifying transactions, including virtual asset transfers when applicable. We actively monitor the evolution of FinCEN guidance on the Travel Rule for virtual-asset service providers.

7. Transaction monitoring

All transactions are subject to rule-based monitoring and, where applicable, analytical models. Factors evaluated include:

  • Notional value and frequency relative to the client's profile
  • Origin and destination jurisdictions
  • Commercial pattern and consistency with declared activity
  • Typical patterns of structuring, smurfing, pass-through and trade-based money laundering
  • Outcome of recurring screenings

Transactions that trigger alerts are reviewed by a compliance analyst and, where necessary, escalated to the Compliance Officer.

8. Regulatory reports

8.1 Suspicious Activity Reports (SAR)

Cloud Excel files SARs with FinCEN per 31 CFR § 1022.320 whenever potentially suspicious activity is identified. SARs are confidential by law and Cloud Excel does not notify clients of the existence of a SAR.

8.2 Currency Transaction Reports (CTR)

CTRs are filed per 31 CFR § 1022.310 for physical currency transactions aggregated above US$ 10,000 in a single business day.

8.3 Blocked Property Reports and Reject Reports

Blocks and rejections under OFAC authority are reported per 31 CFR §§ 501.603 and 501.604.

9. Record retention

Cloud Excel retains all required records for a minimum of 5 years from the end of the relationship or the execution of the transaction, per 31 CFR § 1010.430.

10. Anti-Bribery and FCPA

Cloud Excel applies a formal compliance policy under the Foreign Corrupt Practices Act (15 U.S.C. §§ 78dd-1 et seq.) and the UK Bribery Act. Transactions involving foreign government officials, state-owned enterprises or suspected facilitation payments are escalated for senior review and may be declined.

11. Cooperation with authorities

Cloud Excel cooperates fully with FinCEN, OFAC, the Florida Office of Financial Regulation, IRS, Department of Justice, law enforcement authorities and other competent bodies. We respond to subpoenas, court orders, 314(a) and 314(b) requests and other legal requests in compliance with applicable law.

12. Training

Directors, employees and providers with access to client data receive AML/BSA/OFAC training upon onboarding and periodically, with materials updated in line with the evolution of regulation and risks.

13. Whistleblower & compliance hotline

Employees, clients, partners or any person who becomes aware of suspected violations of Cloud Excel's AML/BSA/OFAC/FCPA policies may report confidentially via compliance@cloud-excel.com. Cloud Excel applies a formal non-retaliation policy toward good-faith whistleblowers.

14. Declined clients

Cloud Excel reserves the right to decline, suspend or terminate any commercial relationship at its sole discretion, without prior notice where permitted by law, whenever risk is identified that is incompatible with our risk appetite or in compliance with regulatory obligations.

15. Complaints

Complaints should first be directed to Cloud Excel via contact@cloud-excel.com. If unresolved:

Florida Office of Financial Regulation
200 East Gaines Street, Tallahassee, FL 32399-0376
+1 (850) 487-9687 · flofr.gov

16. Contact

Cloud Excel LLC — Compliance Department
2801 NW 74th Avenue, Suite 208
Miami, FL 33122 — United States
Phone: +1 (305) 333-0780
Email: compliance@cloud-excel.com

17. Nature of this Policy

This AML / BSA Policy Statement is a public summary of Cloud Excel's compliance program. The formal internal program — with detailed rules, thresholds, investigative procedures, controls and red flags — is confidential for security and regulatory effectiveness reasons and is not disclosed publicly.

18. Language prevalence

The English version of this AML / BSA Policy Statement prevails in case of any inconsistency with translations into Portuguese, Spanish, Mandarin or any other language.