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Anti-Money Laundering Policy - Vida Sabia

ANTI-MONEY LAUNDERING POLICY

(AML Policy)

Vida Sabia - Committed to Financial Integrity

Fecha de entrada en vigor: Octubre 2025

🛡️ Our Commitment to Compliance

Vida Sabia is committed to preventing money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy is established to ensure compliance with the Bank Secrecy Act (BSA), the U.S. PATRIOT Act, and other applicable international regulations.

1PROPÓSITO

This policy is designed to:

  • Prevent money laundering and terrorist financing activities
  • Ensure compliance with U.S. and international AML regulations
  • Establish clear procedures for identifying and reporting suspicious activities
  • Protect Vida Sabia and its stakeholders from financial crimes
  • Maintain the integrity of our financial systems and business operations

2ALCANCE

Who Does This Policy Apply To?

This policy applies to all individuals and entities associated with Vida Sabia, including:

  • All employees and staff members
  • Independent Brand Partners (IBPs)
  • Contractors and consultants
  • Business partners and affiliates
  • Third-party service providers

3MONEY LAUNDERING DEFINITION

Money laundering involves concealing the origin of illegally obtained funds to make them appear legitimate. It generally consists of three stages:

1

Placement

Introduction of illicit funds into the financial system through various means such as deposits, purchases, or currency exchanges.

2

Layering

Conducting multiple transactions to obscure the origin of the funds, making it difficult to trace back to the illegal source.

3

Integration

Reintroducing the laundered funds into the economic system as apparently legitimate assets through investments or business activities.

4COMPLIANCE PROGRAM

4.1 AML Compliance Officer

Responsibilities of the AML Compliance Officer

  • Implement and oversee AML policies and procedures
  • Monitor transactions and report suspicious activities
  • Train employees and IBPs on AML compliance
  • Ensure compliance with national and international AML laws
  • Conduct regular risk assessments and audits
  • Maintain communication with regulatory authorities

4.2 Know Your Customer (KYC) Procedures

To prevent money laundering, Vida Sabia verifies the identity of customers, distributors (IBPs), and business partners through:

🆔Government ID

Valid government-issued identification (passport, driver's license, or national ID card)

🏠Proof of Address

Recent utility bill, lease agreement, or bank statement showing current address

💳Payment Verification

Verification of banking/payment information for high-value transactions

4.3 Transaction Monitoring

Red Flags and Warning Signs REPORT IMMEDIATELY

Vida Sabia monitors transactions to identify warning signs, including:

Large or unusual transactions not consistent with normal business activity

Multiple transactions just below reporting thresholds (structuring)

Transactions with high-risk countries or politically exposed persons (PEPs)

Unusual payment methods or rapid movement of funds without clear business purpose

Customers reluctant to provide required identification or documentation

Inconsistent business patterns or transactions that don't match the customer profile

4.4 Record Keeping

Data Retention Requirements

All customer and transaction records will be retained for at least five (5) years, including:

  • Customer identification documents
  • Transaction records and payment details
  • Internal reviews and risk assessments
  • Suspicious Activity Reports (SARs) and supporting documentation
  • Customer due diligence records
  • Communications related to transactions

4.5 Suspicious Activity Reporting (SAR)

Reporting Obligations

Employees and IBPs must report any suspicious transaction to the AML Compliance Officer, who will determine whether to file a Suspicious Activity Report (SAR) with regulatory authorities.

Importante: Do not inform the customer that a SAR has been filed, as this could compromise investigations.

4.6 Training and Awareness

AML Training Program

All employees and IBPs will receive comprehensive AML compliance training to identify and prevent financial crimes.

AML Laws and Obligations

Understanding relevant laws, regulations, and compliance requirements

Identifying Suspicious Activities

Recognizing red flags and warning signs of money laundering

Internal Reporting Procedures

Proper channels and processes for reporting suspicious activities

Case Studies and Examples

Real-world scenarios to enhance understanding and detection skills

5PROHIBITED TRANSACTIONS

Vida Sabia Strictly Prohibits:

  • Accepting payments from unknown or unverified sources
  • Engaging in transactions with individuals or entities on sanctions lists
  • Using cryptocurrencies or anonymous payment methods for high-value transactions without proper due diligence
  • Allowing third parties to use IBP accounts to conduct transactions
  • Processing transactions for customers who refuse to provide required identification
  • Facilitating transactions that appear designed to evade reporting requirements
  • Conducting business with shell companies or entities with unclear ownership structures

6ENFORCEMENT AND SANCTIONS

Consequences of Non-Compliance SERIOUS

Failure to comply with this AML policy may result in:

🚫 Contract Termination

Immediate termination of employment contracts or IBP agreements

📋 Regulatory Reporting

Reporting of violations to legal and regulatory authorities

💰 Financial Penalties

Civil or criminal penalties in accordance with U.S. and international AML laws

⚖️ Legal Action

Criminal prosecution for willful violations or participation in money laundering

🔒 Account Freezing

Immediate freezing of accounts and suspension of all transactions

7POLICY REVIEW AND UPDATES

Ongoing Commitment to Compliance

This AML policy will be reviewed annually and updated as necessary to reflect:

  • Changes in AML regulations and legal requirements
  • Evolving money laundering techniques and threats
  • Business operations and service offerings
  • Feedback from audits and compliance assessments
  • Industry best practices and standards

8CONTACT INFORMATION

AML Compliance Officer

For questions or to report suspicious activities, please contact:

Vida Sabia AML Compliance Officer

Email: support@vida-sabia.com

⚠️ Confidential Reporting

All reports of suspicious activity will be handled with strict confidentiality. Retaliation against individuals who report in good faith is strictly prohibited.

By collaborating with Vida Sabia, all employees, IBPs, and partners agree to comply with this Anti-Money Laundering Policy.

🌱 Zero Tolerance for Financial Crimes

Vida Sabia maintains a zero-tolerance policy for money laundering and terrorist financing. We are committed to maintaining the highest standards of financial integrity and regulatory compliance.

REPORT SUSPICIOUS ACTIVITY

If you suspect money laundering or have AML concerns:

support@vida-sabia.com

Vida Sabia - Financial Integrity is Our Foundation

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