Greentree International, Inc. (“Green Tree”) is the parent company of Amercanex, Inc. Green Tree is not regulated by the Financial Crimes Enforcement Network (FinCen), Bank Secrecy Act (BSA), Commodity Futures Trading Commission (CFTC), Securities Trading Commission (SEC), or any other financial regulatory agency. Amercanex does not accept funds or handle funds. A Third-Party Payment Processor (TPP) collects deposits, makes payments and processes transactions for our customers and members. Although Green Tree is not currently governed by any of the regulatory bodies previously mentioned, compliance policies are with the highest standards.
Green Tree has implemented procedures to cover key areas as part of our Compliance Department. They are as follows:
Know Your Customer (KYC) Onboarding Process Procedures
Amercanex is committed to following the Know Your Customer (KYC) process, and adheres to strict procedures to verify the identity of our customers. Amercanex has implemented detailed onboarding procedures. During a customer’s onboarding process, Amercanex collects and verifies documentation to substantiate the customer’s identity. Amercanex uses this information to implement Amercanex’s Anti-Money Laundering (AML) policy. Although Amercanex is not financial institution, it has opted to participate in a Customer Identification Program (CIP). For regulated financial institutions, CIP is a provision of the USA Patriot Act and is incorporated as part of the Bank Secrecy act/ AML Compliance Program.
Summary of the Anti-Money Laundering Compliance Program
Amercanex maintains a strict policy against money laundering and is fully committed to following applicable laws, rules and regulations as if it were a regulated entity. To ensure that Amercanex facilities are not used for money laundering purposes, the company maintains an anti- laundering compliance program, which (i) requires employees to gather certain information regarding the true identity of customers, and (ii) requires employees to report suspicious customers and transactions to the designated Amercanex supervisory personnel, principles and/or the Chief Compliance Offices.
Amercanex also requires that appropriate personnel complete an annual training session, which focuses on Amercanex policy and procedures and current laws regarding anti-money laundering. Amercanex shall maintain records of the subject matters discussed and persons in attendance at annual training programs.
DISASTER RECOVERY PLAN
Amercanex has adopted policies and procedures to ensure that any disruption of its business, whether it be caused by a natural disaster, terrorism or otherwise, is minimized and that it is able to resume its business activities promptly. While such disasters cannot be prevented, the adoption of the procedures will allow Amercanex business to recover promptly so that it can resume serving its clients. Amercanex’s goal is to respond to a Significant Business Disruption (SBD) by safeguarding the lives of its personnel, protecting all Amercanex books and records, and allowing clients to continue transacting business.
Although Amercanex is not a licensed cannabis company in any state or International Jurisdiction in which it operates, Amercanex clearly understands that our customers are licensed participants in their respected States of Origin or International Jurisdiction.
Amercanex attest to awareness and understanding that regardless of the State of Origin’s laws, cannabis is still considered a controlled substance by the Controlled Substance Act (CSA) within the jurisdiction of the United States.
Our ACE Marketplace and the services which we provide are intended to help meet the obligations that our members and customers have under the laws of their State of Origin or International Jurisdiction. Each customer and/or member’s jurisdiction has regulations that are specific to both recreational and medicinal marijuana. Amercanex is aware and intends to comply with all laws, rules and regulations that that govern cannabis transactions.