Ledger Tokens Corporation (LTC) Compliance Program Letter

November 18, 2022

To Whom It May Concern:
As a valued LTC partner or affiliate, we wanted to provide you with information about our Bank Secrecy Act (BSA) and Anti Money Laundering (AML) compliance programs.
Our BSA and AML compliance program is designed to ensure that we adhere to all relevant laws and regulations regarding the detection and prevention of money laundering activities. By implementing robust measures, such as customer due diligence and transaction monitoring, we strive to maintain the highest level of integrity in our financial operations.
LTC is a diversified financial services provider headquartered in Maryland and incorporated in Delaware. LTC, along with its subsidiaries and affiliates, follows all regulations set by the U.S. Federal Reserve Board. Its subsidiaries in the United States follow regulations by several regulatory agencies, including, but not limited to, the Office of the Comptroller of the Currency (OCC), the Financial Crimes Enforcement Network (FinCEN), and the Financial Industry Regulatory Authority (FINRA). These regulatory agencies ensure that LTC and its subsidiaries comply with anti-money laundering laws, maintain adequate capital reserves, and adhere to fair trading practices. By following these regulations, LTC demonstrates its commitment to maintaining a transparent and secure financial environment for its clients and stakeholders.
As part of LTC’s compliance programs, we have implemented an Enterprise Financial Crimes Compliance (EFCC) team that oversees LTC and its subsidiaries’ compliance with AML and Economic Sanctions (ES) programs.
EFCC has implemented AML programs consisting of written policies and procedures to comply with applicable domestic AML laws and regulations, including the BSA, the Money Laundering Control Act, and the USA Patriot Act. These programs are designed to detect and prevent money laundering and the financing of terrorism within LTC and its subsidiaries. Additionally, the EFCC team regularly conducts training sessions to ensure that employees are aware of their responsibilities and obligations under these AML programs.
LTC’s AML program requires risk assessments of potential money laundering, systems of internal controls reasonably designed to achieve compliance with legal and regulatory requirements, training and awareness processes, and risk-based independent testing of the Programs. LTC and its subsidiaries cooperate fully with law enforcement and regulatory investigations and inquiries concerning AML matters.
In addition, LTC’s AML program also includes the implementation of customer due diligence measures, such as verifying the identity of customers and monitoring their transactions for suspicious activity. These measures help to ensure that LTC remains vigilant in detecting and preventing money laundering activities within its operations. Furthermore, LTC regularly reviews and updates its AML program to adapt to evolving regulations and industry best practices, demonstrating its commitment to maintaining a strong compliance framework. LTC embraces the highest standards of ethics, integrity, risk management, and compliance and remains committed to improving our controls and processes across the enterprise to protect all our stakeholders. We regularly conduct internal audits and assessments to ensure that our AML programs are effective and up to date. Additionally, we continuously invest in training our employees to enhance their understanding of AML regulations and their role in preventing money laundering activities.

LTC embraces the highest standards of ethics, integrity, risk management and compliance, and remains committed to improving our controls and processes across the enterprise to protect all of our stakeholders.


Hanna Chakarji

Chief Executive Officer