Welcome to the Anti-Money Laundering (AML) Policy of Empresario Capital Group, LLC ("Empresario," "we," "us," or "our"), a Florida company. This policy outlines our commitment to preventing money laundering and terrorist financing in connection with our life insurance products and investment services offered through theempresario.com and empresario.us (collectively, the "Websites").

For questions or concerns regarding this policy, please contact us at legal@theempresario.com.

Last Updated: March 25, 2025

Our Commitment

Empresario Capital Group, LLC is dedicated to complying with all applicable anti-money laundering laws and regulations. We have implemented this AML Policy to detect, prevent, and report any attempts to use our services for illegal activities, including money laundering, terrorist financing, or other financial crimes.

Scope of This Policy

This policy applies to all transactions and interactions involving our life insurance products (e.g., term life, whole life, universal life) and investment services (e.g., mutual funds, annuities). It covers our employees, agents, customers, and third-party partners.

Know Your Customer (KYC) Procedures

To prevent illicit activities, we adhere to Know Your Customer (KYC) standards by:

- Verifying the identity of customers before offering life insurance or investment products, using government-issued identification, proof of address, or other required documents.

- Screening customers against sanctions lists, watchlists, and politically exposed persons (PEP) databases.

- Monitoring customer transactions for unusual or suspicious patterns.

Prohibited Activities

We prohibit the use of our services for:

- Laundering money derived from illegal activities.

- Financing terrorism or other criminal enterprises.

- Concealing the origin, ownership, or destination of funds.

Any attempt to engage in these activities will result in immediate termination of services and reporting to appropriate authorities.

Monitoring and Detection

We employ systems and procedures to monitor customer activity, including:

- Reviewing large or unusual transactions, such as significant premium payments or investment deposits.

- Tracking patterns that may indicate structuring (e.g., breaking transactions into smaller amounts to avoid detection).

- Investigating discrepancies between customer-provided information and observed behavior.

Reporting Suspicious Activity

If we detect suspicious activity, we will:

- File Suspicious Activity Reports (SARs) with the Financial Crimes Enforcement Network (FinCEN) as required by the Bank Secrecy Act (BSA).

- Cooperate fully with law enforcement and regulatory agencies, including the Florida Office of Insurance Regulation and federal authorities.

- Refrain from notifying customers of such reports, in compliance with legal obligations.

Employee Training

Our employees and agents receive regular training on AML laws, red flags for money laundering, and our internal procedures. This ensures they can identify and respond to potential risks effectively.

Record-Keeping

We maintain records of customer identification, transactions, and AML-related investigations for at least five years, as required by law. These records are securely stored and available for review by regulators upon request.

Third-Party Partners

We require our service providers, such as payment processors or investment custodians, to comply with AML regulations. We conduct due diligence on these partners to ensure they maintain appropriate safeguards against money laundering.

Regulatory Compliance

As a Florida company, we comply with:

- The Bank Secrecy Act (BSA) and its implementing regulations.

- The USA PATRIOT Act provisions related to financial institutions.

- Florida state laws governing insurance and investment services.

- Oversight from the Florida Office of Insurance Regulation and, where applicable, the U.S. Securities and Exchange Commission (SEC).

Customer Responsibilities

Customers are expected to provide accurate and truthful information during the KYC process and to use our services only for lawful purposes. Failure to comply may result in account suspension or termination.

Governing Law

This AML Policy is governed by the laws of the State of Florida, USA, without regard to its conflict of law principles. Any disputes related to this policy shall be resolved in the state or federal courts located in Florida.

Changes to This Policy

We may update this AML Policy to reflect changes in laws, regulations, or our business practices. Updates will be posted on this page with a revised "Last Updated" date. Your continued use of our services after such changes indicates your acceptance of the updated policy.

Contact Us

If you have any questions, concerns, or reports of suspicious activity related to this AML Policy, please reach out to us at legal@theempresario.com.

Thank you for your cooperation. Empresario Capital Group, LLC is committed to maintaining a secure and compliant environment as a Florida-based provider of life insurance and investment services.