Anti-Money Laundering (AML) Policy

Anti-Money Laundering (AML) Policy

1. Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to prevent The Watch Aficionado, including its physical retail operations and its website thewatchaficionado.com, from being used to facilitate money laundering, terrorist financing, or other financial crimes. This policy demonstrates our commitment to full compliance with applicable U.S. federal and state laws, including the Bank Secrecy Act (BSA) and related AML regulations.

2. Scope

This policy applies to:

  • The Watch Aficionado retail store operations

  • All employees, contractors, and management

  • All customers and transactions

  • Online sales and inquiries conducted through thewatchaficionado.com

  • Cash, wire, credit card, digital, and alternative payment transactions

3. Regulatory Framework

The Watch Aficionado complies with all applicable AML laws and regulations, including but not limited to:

  • Bank Secrecy Act (BSA)

  • USA PATRIOT Act

  • FinCEN regulations

  • State and local anti-financial crime requirements

4. Risk-Based Approach

The Watch Aficionado adopts a risk-based approach to AML compliance by identifying, assessing, and mitigating risks related to:

  • High-value luxury watch transactions

  • Cash-intensive purchases

  • International customers or shipping destinations

  • Politically Exposed Persons (PEPs)

  • Unusual or complex transaction patterns

5. Customer Due Diligence (CDD)

5.1 Customer Identification

For applicable transactions, The Watch Aficionado may collect and verify customer information, including:

  • Full legal name

  • Government-issued photo identification

  • Date of birth

  • Residential or business address

  • Payment method details

5.2 Enhanced Due Diligence (EDD)

Enhanced due diligence may be conducted for higher-risk customers or transactions, including:

  • High-value purchases

  • Repeated cash transactions

  • Requests for anonymity or third-party payments

  • International transactions or shipping

6. Transaction Monitoring

The Watch Aficionado monitors transactions for suspicious activity, including but not limited to:

  • Structuring or attempts to avoid reporting thresholds

  • Unusual payment methods or combinations

  • Rapid resale requests or inconsistent customer behavior

  • Transactions with no apparent lawful purpose

7. Cash Transactions

  • Cash transactions exceeding applicable regulatory thresholds will be documented and reported as required by law.

  • The Watch Aficionado reserves the right to refuse large cash transactions or request alternative payment methods.

8. Online Sales and Website Compliance

For transactions conducted through thewatchaficionado.com:

  • Customer identity verification may be required prior to order fulfillment

  • Orders may be delayed or canceled pending AML review

  • IP address, payment data, and shipping information may be reviewed for risk indicators

9. Recordkeeping

The Watch Aficionado maintains records of:

  • Customer identification information

  • Transaction details

  • Payment records

  • AML reviews and internal reports

Records are retained for a minimum of five (5) years or longer as required by law.

10. Suspicious Activity Reporting

Any employee who identifies suspicious activity must promptly report it to management or the designated AML Compliance Officer. The Watch Aficionado will file Suspicious Activity Reports (SARs) with appropriate authorities when required.

11. Employee Training

All relevant employees receive periodic AML training, including:

  • Recognizing suspicious transactions

  • Customer due diligence procedures

  • Reporting obligations

  • Confidentiality requirements

12. Compliance Officer

The Watch Aficionado designates an AML Compliance Officer responsible for:

  • Implementing and maintaining this policy

  • Monitoring compliance

  • Conducting internal reviews

  • Serving as the point of contact with regulators

13. Confidentiality

All AML-related investigations and reports are confidential. Employees are prohibited from disclosing the existence of any investigation or report to customers or third parties.

14. Enforcement and Disciplinary Action

Failure to comply with this AML Policy may result in disciplinary action, up to and including termination, and may expose individuals to civil or criminal penalties.

15. Policy Review and Updates

This AML Policy is reviewed at least annually and updated as necessary to reflect changes in laws, regulations, or business operations.

16. Acceptance

By conducting business with The Watch Aficionado, customers acknowledge and agree to comply with applicable AML laws and this policy.

The Watch Aficionado

Effective Date: 1/20/2026