Steadworth Bank Secrecy Act / Anti-Money Laundering Compliance Policy and Program

I. Introduction

Steadworth, LLC ("Steadworth") is committed to conducting its business in compliance with all applicable laws and regulations, including the Bank Secrecy Act ("BSA") and its implementing regulations, including the Anti-Money Laundering ("AML") regulations. This Compliance Policy and Program ("Policy") outlines Steadworth's commitment to preventing money laundering and other financial crimes.

II. Purpose

The purpose of this Policy is to:

• Establish a comprehensive framework for Steadworth's BSA/AML compliance program.

• Prevent Steadworth from being used for money laundering or other financial crimes.

• Protect the integrity of the financial system.

• Comply with all applicable BSA/AML laws and regulations.
  
  

III. Scope

This Policy applies to all Steadworth employees, officers, directors, and agents. It covers all aspects of Steadworth's business operations, including customer onboarding, transaction processing, and risk management.

IV. Responsibilities

A. Compliance Officer:

• The Compliance Officer is responsible for overseeing and implementing Steadworth's BSA/AML compliance program.

• This includes developing and maintaining policies and procedures, conducting risk assessments, providing training to employees, and monitoring compliance with the program.
  
  

B. Senior Management:

• Senior management is responsible for providing adequate resources and support for the BSA/AML compliance program.

• This includes ensuring that the Compliance Officer has the necessary authority and resources to carry out their responsibilities.
  
  

C. All Employees:

• All employees are responsible for complying with this Policy and reporting any suspicious activity to the Compliance Officer.
  
  

V. Compliance Program Elements

Steadworth's BSA/AML compliance program includes the following elements:

A. Risk Assessment:

• Steadworth conducts a risk assessment to identify and assess the money laundering and terrorist financing risks associated with its business operations.

• This risk assessment is reviewed and updated periodically.
  
  

B. Customer Due Diligence:

• Steadworth implements customer due diligence measures to identify and verify the identity of its customers.

• This includes collecting and verifying customer information, such as name, address, and date of birth.
  
  

C. Beneficial Ownership Identification:

• Steadworth identifies and verifies the beneficial owners of its customers.

• This includes identifying individuals who own or control 25% or more of a customer's equity interests.
  
  

D. Transaction Monitoring:

• Steadworth monitors transactions for suspicious activity.

• This includes monitoring for transactions that are unusual or inconsistent with a customer's known activity.
  
  

E. Suspicious Activity Reporting:

• Steadworth employees are required to report any suspicious activity to the Compliance Officer.

• The Compliance Officer will investigate suspicious activity and file Suspicious Activity Reports ("SARs") with the Financial Crimes Enforcement Network ("FinCEN") as required.
  
  

F. Recordkeeping:

• Steadworth maintains records of customer information and transactions as required by the BSA/AML regulations.
  
  

G. Training:

• Steadworth provides regular training to its employees on BSA/AML compliance.

• This training covers topics such as how to identify suspicious activity and how to report it.
  
  

VI. Reliance on Third-Party Service Providers

Steadworth utilizes Plaid, a third-party service provider, for capturing financial and identity data for its users. Plaid has its own extensive AML structure and compliance program in place. Steadworth relies on Plaid's AML program to supplement its own program and mitigate risks associated with customer onboarding and transaction processing. However, Steadworth remains ultimately responsible for ensuring compliance with all applicable BSA/AML laws and regulations.

VII. Review and Revision

This Policy will be reviewed and revised periodically to ensure that it remains current and effective.

VIII. Conclusion

Steadworth is committed to maintaining a strong BSA/AML compliance program. This Policy is intended to provide a framework for that program and to ensure that all employees are aware of their compliance obligations.

IX. Contact

Any questions or concerns regarding this Policy should be directed to the Compliance Officer at: contact@steadworth.com