Anti-Money Laundering (AML) and Sanctions Compliance Policy

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Effective Date: May 28, 2025
Last Reviewed: September 1, 2025

Pick It Up Logistics, Inc. (“Pick It Up Logistics,” “we,” or “our”) is committed to maintaining the highest ethical standards and complying with all applicable Anti-Money Laundering (AML) and sanctions laws and regulations, including those enforced by the Office of Foreign Assets Control (OFAC). This policy establishes a framework to prevent our freight brokerage services from being misused for money laundering, terrorism financing, or sanctions evasion.

• AML Compliance Officer (AMLCO): Pick It Up Logistics shall appoint a designated AML Compliance Officer responsible for administering this program, ensuring day-to-day compliance, conducting training, and serving as the point of contact for regulatory agencies.
   
• Independent Testing: The AML and sanctions program will undergo independent testing annually, conducted by internal audit staff or an independent third party, to assess effectiveness.
   
• Risk Assessment: The company will conduct periodic risk assessments to identify vulnerabilities in its operations, considering customers, carriers, shipping lanes, and geographic exposure. Risk findings will guide the application of due diligence measures.
   

• Identify and Verify: Collect and verify the identity of all shippers, carriers, and third-party logistics providers (3PLs), including names, addresses, USDOT, and/or MC numbers.
   
• Red Flag Indicators: Be alert for inconsistencies, such as frequent company name changes, mismatched documentation, or refusal to provide required information.
   
• Technology Use: Leverage digital platforms to automate ID verification, insurance validation, and operating authority checks.
   

• Automated Screening: Screen all parties at onboarding and continuously against sanctions lists (e.g., OFAC’s Specially Designated Nationals and Blocked Persons List).
   
• Blocked Transactions: Immediately block and report transactions involving sanctioned parties, freezing assets as required by law.
   

• Customer Risk Profiles: Assign risk ratings to customers based on their business model, geography, and transaction activity.
   
• Suspicious Activity: Monitor for transactions that deviate from established patterns or show hallmarks of illicit activity.
   
• Enhanced Due Diligence (EDD): Apply additional scrutiny to high-risk customers or those in high-risk jurisdictions.
   

Red flags requiring escalation include:

• Unusual or last-minute shipping instructions.
   
• Multi-party transactions in high-risk jurisdictions without a clear business purpose.
   
• Use of complex or unusual payment structures.
   
• Shipments routed through sanctioned countries.
   
• Altered or incomplete documentation.
   

• File SARs with the Financial Crimes Enforcement Network (FinCEN) for suspicious transactions of $5,000 or more.
   
• Include a detailed narrative outlining reasons for suspicion.
   
• Maintain strict confidentiality and avoid “tipping off” involved parties.
   

• Currency Transaction Reports (CTRs): File for cash transactions over $10,000.
   
• Funds Transfer Records: Retain details of all transactions involving $3,000 or more, including wire transfers.
   

• Provide mandatory annual AML and sanctions compliance training for relevant employees.
   
• Training will emphasize recognizing red flags, proper escalation, and regulatory obligations.
   

• Retain all AML-related records—including CIP data, transaction records, and SAR filings—for at least five (5) years.
   
• Records must be easily retrievable for regulatory review, in paper or electronic format.
   

Employees who fail to comply with this policy are subject to disciplinary action, up to and including termination. Non-compliance may also expose the company and its employees to severe civil and criminal penalties, including fines and imprisonment.

• Employees are required to report suspected policy violations to the AML Compliance Officer immediately.
   
• Retaliation against good-faith reporting is strictly prohibited.
   

• Bank Secrecy Act (BSA) – AML compliance framework.
   
• OFAC Sanctions Guidance – U.S. Department of the Treasury.
   
• FinCEN Guidance – Suspicious activity reporting requirements.
   

AML Compliance Officer
Pick It Up Logistics, Inc.
320 W Lanier Avenue, Suite 200
Fayetteville, GA 30214
Phone: +1 (866) 725-4877
Email: Admin@pickituplogistics.net