1. Purpose

The purpose of this policy is to define the procedures, standards, and controls that Stonewood Global LLC ("Stonewood Global") follows to ensure compliance with anti-money laundering (AML), counter-terrorism financing (CTF), and sanctions regulations, as well as to clearly communicate how client funds are handled in the course of procurement and consultancy services.

2. Scope

This policy applies to:

• All client funds managed or processed by Stonewood Global in connection with procurement projects.
• All employees, agents, and representatives involved in client fund handling or supplier payment facilitation.
• All transactions involving domestic and international suppliers.

3. Source of Funds

• All funds processed through Stonewood Global originate from contractual payments made by clients for approved procurement projects.
• Stonewood Global does not solicit or accept funds from unknown third parties.
• Funds are never used for purposes outside the scope of the contracted project.

4. Purpose of Transfers

• Funds are used exclusively for settling approved supplier invoices and executing procurement and consultancy services.
• No funds are used for speculative investment, unrelated business activities, or personal gain.
• International transfers are conducted solely to facilitate global procurement projects where suppliers are located outside the United States.

5. Funds Handling Practices

• Stonewood Global does not handle cash or cryptocurrency.
• Stonewood Global does not operate as a bank, escrow, or financial institution.
• Stonewood Global does not accept third-party remittances.
• Client funds are kept separate from Stonewood Global's operational funds and are only disbursed to suppliers in accordance with signed project agreements.

6. Compliance & Regulatory Standards

• Stonewood Global is committed to AML, CTF, and sanctions compliance, in line with international standards.
• All transactions are monitored and screened for compliance with sanctions lists, including but not limited to:
  • OFAC (US Office of Foreign Assets Control)
  • UN Sanctions
  • EU and UK Sanctions Lists
• Stonewood Global maintains documentation for all transactions to ensure traceability, audit readiness, and regulatory transparency.

7. Role of Stonewood Global

• Stonewood Global acts strictly as a procurement and consulting agent.
• The company does not take ownership of client funds or goods.
• Funds are processed on behalf of clients only and are disbursed to pre-approved suppliers under project agreements.

8. Transaction Volume

• Transaction volumes typically range between USD 200,000 and USD 1,000,000 per month, depending on active project milestones, supplier invoices, and delivery schedules.
• The volume is project-based, legitimate, and documented.

9. Recordkeeping and Audit

• Stonewood Global maintains detailed records of all client funds, supplier invoices, and transaction authorizations.
• Records are retained in accordance with regulatory requirements and made available for auditing by regulators or banking partners when required.

10. Policy Review

This policy is reviewed annually or as required to ensure compliance with applicable laws, regulations, and best practices.