AML Policy

Anti-Money Laundering and Counter-Financing of Terrorism (AML/CFT) Policy

Last Review: 2026

Corporate Commitment Statement

Photon Rush maintains a zero-tolerance mandate regarding financial crime. As a strategic service provider registered and operating under the laws of Costa Rica, we are committed to the highest ethical and legal benchmarks. We ensure our corporate infrastructure is never utilized as a conduit for illicit financial activities.

This policy establishes the formal frameworks and control mechanisms required to identify and mitigate risks associated with money laundering and the financing of terrorism, ensuring the total integrity of our business operations.

Regulatory Framework and Scope

This policy is binding for all Photon Rush employees, directors, consultants, and strategic partners. Our compliance structure is strictly aligned with:

Law No. 8204 (Comprehensive Reform of the Law on Narcotics, Psychotropic Substances, Drugs of Unauthorized Use, Related Activities, Money Laundering and Financing of Terrorism).

Law No. 7786, as amended and supplemented by the reforms of Law 8204, 8719, and 9449.

The international recommendations of the Financial Action Task Force (FATF/GAFI).

While Photon Rush operates as a technology and strategic consulting firm, we acknowledge the potential risks within the service sector. Under Law 8204, we proactively apply enhanced due diligence to all commercial relationships to prevent the legitimization of capital from illicit sources.

Operational Definitions

Money Laundering: The process of masking the illicit origin of capital to integrate it into the legal economy.

Terrorist Financing: The provision or collection of funds with the intent or knowledge that they will support criminal organizations or terrorist acts.

Beneficial Ownership: The natural person(s) who ultimately owns or controls a client and/or the natural person on whose behalf a transaction is being conducted.

Prevention and Compliance Protocols

To maintain a secure environment, Photon Rush operates under these four pillars:

Know Your Customer (KYC): Rigorous identification of clients and legal representatives, as mandated by Article 15 bis of Law 8204 for professional service providers.

Risk-Based Approach (RBA): Allocating resources to monitor transactions and clients that present a higher risk profile.

Record Keeping: Systematic retention of all transactional and identification documents for a minimum of five years, as required by Costa Rican legislation.

Institutional Integrity: Continuous training for our staff to recognize and report suspicious activity to the appropriate authorities

Client Obligations

Full transparency is a prerequisite for any professional engagement with Photon Rush. In compliance with Law 8204, clients are formally required to:

Certify the legitimate origin of all funds used for the payment of services.

Provide updated documentation regarding corporate structure and Beneficial Ownership.

Guarantee that services are not utilized for activities violating local or international statutes.

Note: Evidence of document falsification or suspicious behavior grants Photon Rush the right to terminate all services immediately, without notice or reimbursement.

Strict Prohibitions

The following practices are expressly forbidden:

Engaging services through shell companies or opaque legal structures that prevent the identification of the final beneficiary.

Payments executed by third parties not formally linked to the service contract.

Transactions involving individuals or entities listed on international sanctions lists, including OFAC and UN designations.

Reporting and Compliance

Any activity suspected of violating these standards must be reported through our confidential channel:

Compliance Unit: compliance@photonrush.cr

In accordance with Law 8204, Photon Rush will fulfill its legal duty to report suspicious transactions (STR/ROS) to the Financial Intelligence Unit (UIF) of the Instituto Costarricense sobre Drogas (ICD).

Policy Governance

This document is reviewed semi-annually to ensure alignment with evolving financial regulations and crime typologies in Costa Rica. Modifications become effective immediately upon their official publication.