Effective Date: 2026-05-29 · Version 1.0
1. Commitment
Troy Accounting does not knowingly accept or facilitate proceeds of crime, money laundering, terrorist financing, or transactions designed to evade U.S. or international sanctions.
2. Client Onboarding
New engagements require verification of: business legal name, formation jurisdiction, EIN, ultimate beneficial owners (25%+), nature of business, and source of funds where the engagement profile warrants. We retain documentation in accordance with FinCEN guidance and applicable state rules.
3. Sanctions Screening
We screen prospective and active clients against OFAC SDN, Consolidated Sanctions, FBI Most Wanted, and equivalent EU/UK lists at onboarding and at periodic intervals.
4. Beneficial Ownership
In accordance with the Corporate Transparency Act and FinCEN BOI requirements, we collect and maintain beneficial-ownership information necessary to perform engagement work, and we support clients in their own BOI reporting obligations.
5. Suspicious Activity
Staff are trained to recognize indicators of suspicious activity. Where reportable, we cooperate fully with law enforcement, FinCEN, and the IRS, consistent with our professional obligations and applicable privilege protections.
6. Decline Right
We reserve the right to decline or terminate any engagement where AML, sanctions, or ethics concerns arise, with reasonable notice and without further explanation beyond what is legally required.
7. Industry Exclusions
Our practice declines engagement with industries we identify on the Industries page, including adult entertainment, gambling, cannabis, tobacco/vape, firearms, payday lending, cryptocurrency exchanges, and multi-level marketing.
8. Compliance Officer
AML inquiries: info@troyaccounting.net with subject "AML Compliance".