Anti Money Laundering Policy

Policy Statement

It is the policy of the Day At The Track, Inc. ("DATT") to comply with applicable provisions of the Money Laundering Control Act of 1986, the Bank Secrecy Act, the USA PATRIOT Act of 2001, the rules and regulations overseen by the United States Treasury Department's Office of Foreign Assets Control, and other anti-money laundering obligations imposed by federal and other statutes.

Reason for Policy/Purpose

The purpose of this policy is to enhance the DATT's compliance with anti-money laundering laws and regulations, to assist law enforcement in combating illegal money laundering, and to minimize the risk of university resources being used for improper purposes. Failure to comply with anti-money laundering regulations could result in civil and criminal penalties to the university and/or individual employees.

Who Needs to Know This Policy

All Officers, Directors and Staff.

Policy/Procedures

Money laundering is conducting or attempting to conduct a financial transaction knowing that the transaction is designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the proceeds of specified unlawful activity. To assist the federal government in detecting, preventing and eradicating criminal and terrorist financing and activity, the university will evaluate all financial transactions and take all necessary steps to comply with applicable anti-money laundering laws and regulations.

All funds received by DATT should be deposited into our bank account at Metro Phoenix Bank, Phoenix, AZ 85008. Any concerns regarding transactions that are unusually large or that appear suspicious and questions regarding money laundering in general should be directed to the CEO immediately. Potential violations of this policy should be reported to the CEO as well.

Related Information

31 U.S.C. §5311 et seq., §5326 and §5331 31 C.F.R. §103.11 et seq. §103.20-30 and §103.125 Bank Secrecy Act, 12 U.S.C. §1951, et seq. Money Laundering Control Act of 1986 USA PATRIOT Act, Public Law 107-56, §314(a)-(b).

Policy Effective Date: March 12, 2014