1. Introduction

Trove Solutions, a Singapore-based company offering employee gift automation software in Southeast Asia is committed to preventing money laundering and terrorist financing activities. This policy outlines our procedures for identifying and mitigating the risks associated with such activities. We comply with all applicable Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) laws and regulations in Singapore and the jurisdictions we operate in.

2. Commitment to AML in Southeast Asia

As a responsible provider of a Software-as-a-Service (SaaS) platform for employee gift automation, Trove Solutions recognizes its role in upholding financial integrity within Southeast Asia. We are dedicated to ensuring our platform is not misused for illegal activity.

3. Risk Assessment

Trove Solutions acknowledges that the nature of our business presents certain AML/CFT risks. This includes, but is not limited to:

• High-value gift transactions (depending on company gifting policies)
• Potential for misuse of company funds for personal gain

We conduct ongoing risk assessments to identify and understand these risks, and adjust our procedures accordingly:

• Combination of automatic and manual checks on suspicious gift transactions, including but not limited to (Section 5: Enhanced Measures for Employee Gift Automation)
• Annual AML/CFT Meeting with AML Committee (Section 10: AML Committee and Escalation Process) to update and improve compliance policies
• Per Singapore laws, Trove is legally required to file Suspicious Transaction Report (STR) to Singapore’s Suspicious Transaction Report Office
• Annual Internal Audit (IA) to review AML/CFT/Sanction Compliance

4. Customer Due Diligence (CDD)

We conduct Customer Due Diligence (CDD) on clients in accordance with local regulations. This may involve:

• Verifying the legitimacy of the company and its business activities.
• Identifying the authorized representatives for Trove account management.