Bank Secrecy Act (BSA) / AML Program Statement

Milli is committed to the highest standards of compliance with the Bank Secrecy Act ("BSA"), the USA PATRIOT Act, sanctions laws administered by the Office of Foreign Assets Control ("OFAC"), and all applicable anti-money laundering ("AML") and counter-terrorist financing laws.

1. Program Overview

Milli maintains a risk-based BSA/AML compliance program, designed in coordination with the BSA/AML programs of its partner bank, that includes the four pillars required by federal regulators plus customer due diligence: 1. Internal policies, procedures, and controls reasonably designed to detect and prevent money laundering and terrorist financing; 2. A designated BSA/AML Compliance Officer responsible for day-to-day oversight of the program; 3. Ongoing employee training for all personnel, with enhanced training for those in compliance, risk, operations, and customer support roles, delivered at onboarding and at least annually; 4. Independent testing of the program at least annually by qualified internal or external parties; and 5. Customer due diligence, including identification and verification of customers and beneficial ownership where applicable.

2. Reporting

Milli monitors activity for indicators of suspicious behavior. Where Milli is subject to reporting obligations, or in support of its partner bank's obligations, Milli escalates, investigates, and reports suspicious activity, including through Suspicious Activity Reports ("SARs"), and supports Currency Transaction Reports ("CTRs") where applicable. SAR information is confidential under federal law.

3. Sanctions Compliance

Milli screens customers against the OFAC Specially Designated Nationals and Blocked Persons List and other applicable lists at onboarding and on an ongoing basis, and blocks or rejects transactions as required.

4. Cooperation with Law Enforcement

Milli cooperates with law enforcement and regulatory agencies, responds to lawful requests, and supports information-sharing requests in accordance with applicable law.

5. Customer Responsibilities

Customers must provide accurate information, may be asked for additional information at any time, and agree not to use Milli for any prohibited activity under our Acceptable Use Policy.

For a full overview, see our FinCEN Compliance Statement. Compliance inquiries: compliance@drivemilli.com.