ANTI-MONEY LAUNDERING (AML) & COMPLIANCE INTEGRITY STATEMENT
At Creed Financial Crimes Compliance Firm, LLC (“Creed,” “we,” “our,” or “us”), we affirm our unwavering commitment to upholding the highest standards of legal, ethical, and regulatory compliance in all aspects of our operations, service delivery, and client engagements. This AML & Compliance Integrity Statement outlines our internal principles, regulatory posture, and the proactive measures we undertake to combat financial crime, uphold global compliance standards, and safeguard financial systems against abuse.
1. Our Core Belief
We believe that transparency, accountability, and compliance are the foundations of trust in any financial, corporate, or public sector environment. As such, Creed’s professional services are guided by the values of integrity, diligence, objectivity, and legal fidelity—particularly in combating:
- Money laundering
- Terrorist financing
- Sanctions evasion
- Fraudulent financial activity
- Bribery and corruption
- Corporate misconduct
2. Global Regulatory Alignment
Creed operates in strict adherence to a range of national and international regulatory frameworks, including but not limited to:
United States (Federal & State-Level)
- Bank Secrecy Act (BSA) – 31 U.S.C. §§ 5311 et seq.
- USA PATRIOT Act
- OFAC Sanctions Programs
- FinCEN Guidelines and SAR Requirements
- Maryland Money Transmitter Act and related financial regulations
International Frameworks
- Financial Action Task Force (FATF) 40 Recommendations
- European Union AML Directives (AMLDs 4, 5, 6)
- UK Proceeds of Crime Act (POCA)
- United Nations Sanctions & Counter-Terrorism Resolutions
As a consultancy, we not only assist our clients in complying with these standards but also apply their principles within our own firm policies, risk assessments, and due diligence protocols.
3. Firm-Level AML & CTF ControlsECT
3.1. Internal AML Governance Structure
Creed has established a robust internal AML governance framework that includes:
- Appointment of a Compliance Officer (CO) responsible for AML oversight
- Regular internal AML risk assessments and compliance audits
- Integration of Know Your Customer (KYC), Customer Due Diligence (CDD), and Enhanced Due Diligence (EDD) protocols in our client onboarding process
3.2. Red Flag Identification & Escalation
Creed personnel are trained to identify suspicious indicators (“red flags”) of potential money laundering, sanctions evasion, or fraud, including:
- Unusual or complex transaction structures
- Incomplete or inconsistent client information
- Requests to circumvent compliance processes
- Interactions involving high-risk jurisdictions or PEPs (Politically Exposed Persons)
All suspected matters are escalated through a formal internal reporting mechanism and, where required, voluntarily reported to relevant authorities.
4. Ethical Independence and Zero Tolerance
Creed operates with strict independence from any client or third party that:
- Attempts to use our services to legitimize illicit assets
- Requests falsification, concealment, or misrepresentation of data
- Demonstrates disregard for ethical or legal standards
We reserve the right to terminate any engagement if red flags indicate misuse of our services for unlawful purposes or if cooperation is refused during necessary compliance procedures.
5. Sanctions Compliance
Creed actively screens all clients, vendors, and relevant third parties against major international sanctions lists, including:
- U.S. Department of the Treasury – OFAC SDN & Non-SDN Lists
- United Nations Security Council Consolidated List
- European Union Consolidated Financial Sanctions List
- UK HM Treasury Sanctions List
Any matches or partial matches are thoroughly investigated prior to engagement. We do not provide services to sanctioned individuals, entities, or countries in violation of U.S. or international law.
6. Training, Awareness & Certification
Creed actively screens all clients, vendors, and relevant third parties against major international sanctions lists, including:
- U.S. Department of the Treasury – OFAC SDN & Non-SDN Lists
- United Nations Security Council Consolidated List
- European Union Consolidated Financial Sanctions List
- UK HM Treasury Sanctions List
Any matches or partial matches are thoroughly investigated prior to engagement. We do not provide services to sanctioned individuals, entities, or countries in violation of U.S. or international law.
7. Client Responsibility and Mutual Obligations
We emphasize that compliance is a shared responsibility. While Creed advises and supports clients in designing or enhancing their AML frameworks, clients are expected to:
- Disclose accurate, complete, and timely information
- Cooperate with CDD/EDD and sanctions screening procedures
- Maintain their own internal AML programs in line with regulatory obligations
Clients using our services for AML program development, internal audits, SAR preparation, or third-party risk reviews must ensure they follow through with implementation and regulatory reporting, where applicable.
8. Whistleblower and Ethics Hotline
Creed promotes a safe and confidential environment for reporting violations, unethical conduct, or potential financial crime. We maintain an internal ethics hotline where team members or third parties may report:
- Suspected misconduct within Creed
- Suspicious activity observed in client interactions
- External misconduct related to financial crime
All reports are handled confidentially and investigated promptly in accordance with internal policies.
9. Continuous Program Evolution
As global threats evolve, so does our approach. Creed commits to:
- Updating internal AML policies based on regulatory alerts and enforcement actions
- Incorporating lessons learned from audits, case studies, and client engagements
- Innovating through technology (e.g., AI-based monitoring, RegTech integration)
We believe that a static compliance program is a vulnerable one. Thus, we evolve continuously to meet emerging threats and strengthen preventive measures.
10. Legal Responsibility and Governing Law
This AML & Compliance Integrity Statement is intended to:
- Fulfill our obligations under U.S. federal and Maryland state law;
- Reflect best practices and due diligence expectations under FATF, OFAC, and FinCEN;
- Be a public expression of Creed’s dedication to global financial integrity.
Any legal matters related to this policy shall be governed by the laws of the State of Maryland, and any claims arising under this statement shall be subject to the exclusive jurisdiction of Maryland courts.
11. Review & Publication
This policy is reviewed and approved by Creed’s Compliance Committee and is:
- Reviewed annually or upon regulatory changes
- Published publicly on our website for transparency
- Distributed internally for awareness and onboarding
Effective Date: 6/23/2025
Last Reviewed: 6/23/2025