Venture Connect LLC (“Venture Connect,” “we,” “us,” or “our”) is committed to conducting business responsibly and to preventing its services from being used for money laundering, terrorist financing, fraud, sanctions evasion, financial crime, or other unlawful activities.
This Anti-Money Laundering Policy (“AML Policy”) describes the principles and controls Venture Connect may apply when onboarding clients, evaluating business relationships, providing payment-related consulting or integration support, facilitating business introductions, and delivering other services.
1. Business Information
Business Name: Venture Connect LLC. Address: 250 West 57th Street, Suite 1301, New York, NY 10107, United States. Phone: +1 214-851-8958. Email: support@venturesconnect.us.
2. Purpose of This Policy
- Reduce the risk of Venture Connect services being used for unlawful activity
- Verify the identity and legitimacy of clients where appropriate
- Understand the nature and purpose of business relationships
- Identify suspicious or inconsistent activity
- Apply enhanced review to higher-risk relationships
- Maintain appropriate records
- Decline or terminate relationships presenting unacceptable risk
- Cooperate with lawful requests from competent authorities where required
3. Scope
This policy may apply to customers and prospective customers, business clients, merchants, business partners, referral partners, vendors and contractors, payment-related consulting clients, businesses introduced to third-party service providers, and other parties with whom Venture Connect establishes a commercial relationship. The level of verification or due diligence applied may vary depending on the nature, value, geography, risk level, and purpose of the relationship.
4. Nature of Venture Connect's Services
Venture Connect may provide eCommerce consulting, website and technology services, payment gateway integration assistance, payment solution consulting, onboarding support, business consulting, strategic partnerships, commercial introductions, and growth and operational support. Unless expressly stated otherwise, Venture Connect does not itself hold or transmit client funds and does not act as a bank, payment processor, card network, acquiring bank, money transmitter, or deposit-taking institution. Any regulated payment or banking services are provided by independent third-party providers under their own compliance programs, terms, and eligibility requirements.
5. Customer Due Diligence
Where appropriate based on the nature and risk of the relationship, Venture Connect may request information to verify a customer or business. For individuals this may include legal name, date of birth, residential address, government-issued identification, contact information, nationality or country of residence, and information about occupation or business activity. For businesses this may include legal business name, registration number, incorporation documents, registered and operating address, website, nature of business, ownership, director or officer information, beneficial ownership information, tax identification details, business licenses, and supporting commercial records.
6. Beneficial Ownership
For business clients, Venture Connect may seek to identify individuals who ultimately own or control the business, including shareholders, beneficial owners, directors, authorized representatives, and individuals exercising significant control. We may request supporting documentation to confirm ownership or control.
7. Know Your Customer and Know Your Business
Venture Connect may perform Know Your Customer or Know Your Business reviews where appropriate to establish who the client is, whether the business exists, what products or services it provides, where it operates, expected activity, source of business revenue, intended use of Venture Connect services, whether the activity appears commercially reasonable, and whether the business presents heightened compliance risk. Verification may be performed directly or with the assistance of third-party verification providers.
8. Risk-Based Approach
Venture Connect may apply a risk-based approach when reviewing clients and business relationships. Factors considered may include country of incorporation or residence, nature of business, industry, products and services, ownership structure, payment activity, expected volumes, customer base, source of funds, use of intermediaries, regulatory status, adverse media, sanctions exposure, previous account suspensions, and unusual or inconsistent business activity. Higher-risk relationships may be subject to additional review.
9. Enhanced Due Diligence
Enhanced Due Diligence may be applied where a customer, business, transaction, or relationship presents increased risk. Additional information may include source of funds or wealth, a detailed business model, customer or supplier information, bank statements, contracts, invoices, payment processor statements, proof of inventory or fulfillment, business licenses, corporate ownership records, and an explanation of transaction patterns. Venture Connect may decline to proceed if satisfactory information cannot be obtained.
10. Source of Funds
Where reasonably necessary, Venture Connect may ask a client to explain or document the source of funds used in connection with a transaction or business relationship. The acceptance of any document is at Venture Connect's discretion and does not constitute verification by a financial institution.
11. Sanctions Screening
Where appropriate, Venture Connect may screen customers, beneficial owners, directors, or counterparties against sanctions or restricted-party lists, including lists maintained by the U.S. Office of Foreign Assets Control, the United Nations, the United Kingdom, the European Union, and other relevant authorities. Venture Connect may reject, suspend, or terminate relationships where sanctions concerns arise.
12. Politically Exposed Persons
Where appropriate, Venture Connect may identify whether a customer or beneficial owner is a Politically Exposed Person, a family member of a PEP, or a close associate. A PEP relationship does not automatically mean unlawful activity is present, but such relationships may require additional due diligence based on risk.
13. Prohibited Activities
Venture Connect will not knowingly support or facilitate services involving money laundering, terrorist financing, fraud, identity theft, stolen payment credentials, sanctions evasion, tax fraud, bribery or corruption, fake or deceptive shell businesses, misrepresentation of ownership, falsified documents, unauthorized account access, payment account trafficking, merchant account renting or leasing, account takeovers, card testing, transaction laundering, unauthorized payment processing, misleading payment applications, concealment of the true nature of a business, circumvention of financial institution restrictions, or other unlawful or deceptive financial activity.
14. Payment Accounts and Merchant Accounts
Venture Connect does not permit its services to be used to obtain or operate payment accounts through false, misleading, or concealed information. Clients must not apply under another person's identity without authorization, misstate beneficial ownership, conceal the actual business model, process payments for unrelated third parties without authorization, use one merchant account for another undisclosed business, attempt to bypass account suspensions, provide altered or forged verification documents, route transactions to disguise their true source, or use payment infrastructure for prohibited products or services. Third-party payment providers make their own independent compliance and onboarding decisions.
15. Suspicious Activity Indicators
Examples of activity that may require further review include unclear or inconsistent ownership information, refusal to provide reasonable verification documents, documents that appear altered, business activity that does not match the stated model, requests to conceal ownership or transaction purpose, unusual transaction patterns, unexplained third-party payments, rapid movement of funds without an apparent commercial purpose, requests to bypass payment provider restrictions, repeated changes in business identity, multiple unrelated businesses using the same payment infrastructure, inconsistencies between website content and stated operations, unusually high-risk jurisdictions, and requests involving false invoices. The presence of one indicator does not necessarily establish wrongdoing but may result in further review.
16. Monitoring and Ongoing Review
Venture Connect may periodically review an ongoing business relationship where appropriate, including changes to business activity, ownership, website content, products or services, transaction patterns, geographic activity, payment arrangements, and risk indicators. We may request updated information when necessary.
17. Refusal or Termination of Service
Venture Connect reserves the right to refuse, suspend, restrict, or terminate services where required information is not provided, information appears false or misleading, verification cannot reasonably be completed, fraud or unlawful activity is suspected, sanctions concerns arise, the business presents an unacceptable level of risk, a customer attempts to circumvent compliance controls, or continuing the relationship could expose Venture Connect to legal, regulatory, financial, or reputational risk. We are not required to disclose internal risk assessments where doing so would be inappropriate or legally restricted.
19. Record Keeping
Venture Connect may maintain records reasonably necessary for compliance, security, dispute resolution, and legitimate business purposes, including identity documents, business documents, verification results, client communications, agreements, invoices, risk assessments, supporting transaction information, and compliance-related correspondence. Records will be retained in accordance with applicable law and our legitimate business requirements.
20. Data Protection
Personal information collected for AML, KYC, KYB, fraud prevention, or security purposes will be handled in accordance with our Privacy Policy and applicable privacy laws. Access to sensitive information may be restricted to authorized personnel or service providers with a legitimate need to access it.
21. Employee and Contractor Responsibilities
Personnel involved in customer onboarding, payment-related services, business partnerships, or higher-risk activities should follow this policy, escalate suspicious circumstances, avoid knowingly facilitating unlawful activity, maintain confidentiality, protect customer information, and follow applicable internal verification procedures. Personnel must not assist a client in bypassing verification, sanctions, fraud prevention, or payment provider controls.
22. Training and Awareness
Venture Connect may provide relevant personnel with training or guidance concerning fraud indicators, money laundering risks, KYC and KYB procedures, sanctions, suspicious activity, escalation procedures, client verification, and data protection. The level of training may depend on the employee's responsibilities.
23. Third-Party Providers
Venture Connect may rely on third-party services for identity verification, business verification, fraud prevention, sanctions screening, payment processing, banking, and compliance technology. These providers may conduct their own independent checks. Venture Connect does not control the outcome of a third party's compliance review.
24. No Guarantee of Approval
Completion of Venture Connect's internal checks does not guarantee that any bank, payment processor, payment gateway, financial institution, marketplace, advertising platform, or technology provider will approve, maintain, or continue providing services to a client. Each third-party provider applies its own eligibility, underwriting, risk, and compliance standards.
25. No Assistance With Circumvention
Venture Connect will not knowingly assist customers with bypassing KYC or KYB, evading sanctions, concealing beneficial ownership, creating deceptive business structures, reapplying to payment providers using false information, disguising a previously restricted business, obtaining accounts using nominees without proper disclosure, processing payments through unrelated businesses, or circumventing merchant account restrictions. Requests of this nature may result in immediate refusal or termination of service.
26. Updates to This Policy
Venture Connect may update this AML Policy periodically. The “Last Updated” date at the top of this policy will be updated when material changes are made.
27. Contact
Questions relating to this AML Policy may be directed to Venture Connect LLC, 250 West 57th Street, Suite 1301, New York, NY 10107, United States. Phone: +1 214-851-8958. Email: support@venturesconnect.us.