| (AML)
ANTI MONEY LAUNDERING AND ANTI-TERRORIST FINANCING POLICY STATEMENT
InfoUSA and its subsidiaries,
EasyTel.Net, Genie Bancor.Com, Dialtel and Universal Office Corporation,
(hereinafter collectively "IUSA") recognize that The International
Money Laundering Abatement and Anti-Terrorist Financing Act of
2001 ("Act") imposes important new obligations on all financial
service firms for the detection, deterrence and reporting of money
laundering activities. Under the Act, money laundering is defined
as any financial transaction using income derived from criminal
activity including, but not limited to, drug trafficking, fraud,
illegal gambling and terrorism. IUSA has established the following
policies to ensure thorough compliance with all laws and regulations
regarding money laundering and anti-terrorist financing.
Prior to the opening of any new
account, which conducts over an aggregate amount of one thousand
dollars, per day, in monetary transactions, IUSA shall document
the identity, nature of business, income, source of assets, and
the objectives of each such prospective customer. Accounts for
persons or entities from countries that do not cooperate with
the Financial Action Task Force (FATF) guidelines on money laundering
and anti-terrorist financing shall be subject to a heightened
level of scrutiny. Accounts in the name of, or related to, any
person or entity on the Office of Foreign Asset Control (OFAC)
Specially Designated Nationals and Blocked Person list will not
be accepted.
On an ongoing basis, IUSA shall
review account activity for evidence of suspicious transactions
that may be indicative of money laundering activities. This review
may include surveillance of: 1) money flows into and out of accounts,
2) the origin and destination of wire transfers, 3) non-economic
transactions, and 4) other activity outside the normal course
of business.
Every officer and employee of
IUSA shall be responsible for assisting in the firm's efforts
to uncover and report any activity that might constitute, indicate
or raise suspicions of money laundering and/or terrorist financing.
To this end, IUSA shall provide continuing education and training
of all such persons.
Should any officer, employee
of IUSA have any knowledge, suspicions or information regarding
any potential of the above activities, that individual shall immediately
notify IUSA's Security Department. IUSA's Security Officer shall
document the reported activity, investigate fully, and, if warranted,
report such activity to the senior management of IUSA.
IUSA shall comply with all trade
and economic sanctions imposed by OFAC against targeted foreign
countries and shall cooperate fully with government agencies,
self-regulatory organizations and law enforcement officials regarding
these matters.
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