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Shabbir Gillani

Shabbir Gillani

Chief Executive Officer

Ali Saberi

Ali Saberi

Founder

Raja Gopal Vemuri

Raja Gopal Vemuri

Chief Technology Officer

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Shahid Husain

Shahid Husain

Chief Operating Officer

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Headquarters
- Terms + Terms | Privacy | - Cookies + Anti-Slavery + | + AML Policy
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Headquarters
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Get Started Today

- Terms + Terms + | Privacy - Anti-Slavery Policy - Cookies + | + Anti-Slavery + | + AML Policy
diff --git a/aml-policy.html b/aml-policy.html new file mode 100644 index 0000000..fff1c71 --- /dev/null +++ b/aml-policy.html @@ -0,0 +1,517 @@ + + + + Tilli AML, Sanctions, and Financial Crime Compliance Policy | Tilli Software + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +
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+ ✨ See how much you could save with Tilli — calculate your ROI in 2 minutes. + +
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Compliance Policy
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Tilli AML, Sanctions, and Financial Crime Compliance Policy

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Last updated: May 11, 2026

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This policy describes Tilli's risk-based onboarding, screening, monitoring, and operational controls designed to reduce misuse of applicable payment, onboarding, disbursement, money-movement, and related Services for money laundering, sanctions evasion, fraud, terrorist financing, or other unlawful financial activity.

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+ United States operations + Utilli LLC (doing business as Tilli) +
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+ India operations + Tilli Software India Private Limited +
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1. Purpose

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Tilli is committed to maintaining risk-based policies, procedures, and controls designed to help prevent the misuse of applicable Services for money laundering, sanctions evasion, fraud, terrorist financing, or other unlawful financial activity.

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2. Covered Entities

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For United States operations, the relevant entity is Utilli LLC (doing business as Tilli). For India operations, the relevant entity is Tilli Software India Private Limited. Those entities are referred to in this policy individually or collectively, as applicable, as Tilli or Tilli Software.

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3. Scope and Applicability

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This policy applies on a risk-based basis to the products, customers, partners, jurisdictions, and workflows for which Tilli reasonably determines AML, sanctions, KYC, KYB, fraud, or financial-crime controls are necessary or appropriate.

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  • TilliPay and payment-related workflows.
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  • Digital disbursements, ACH, settlement, or other money-movement services.
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  • Partner, merchant, vendor, or other direct customer onboarding.
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  • Direct customer or partner accounts involving payment or financial functionality.
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  • Workflow-triggered payment or onboarding actions initiated through Beacon, Nudge, tilliX, JAREIS, or related Tilli Services.
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  • OTP, partner, or referral-party relationships involved in regulated or payments-sensitive services.
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This policy does not assume that every SaaS workflow or every end user of a Tilli customer is Tilli's direct regulated customer. Where Tilli provides software tools to a customer that manages its own end-consumer relationship, Tilli may determine that certain AML, KYC, or onboarding obligations primarily remain with the customer or a regulated partner rather than with Tilli directly.

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4. Governance and Oversight

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Tilli maintains designated responsibility for AML and related financial-crime compliance oversight. Governance responsibilities may include policy ownership, risk assessment, onboarding control design, suspicious-activity escalation, sanctions and fraud monitoring, training coordination, testing, and partner or authority response management.

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5. Risk-Based Customer and Partner Segmentation

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Tilli's compliance controls may vary depending on the relationship and service model. Tilli may distinguish between indirect end users of a customer's workflow, direct customers such as sub-merchants or vendors, partner and referral-party relationships, and higher-risk customers, counterparties, use cases, geographies, or transaction patterns that require enhanced due diligence.

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6. Customer Identification and Due Diligence

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Where applicable, Tilli may require customer, partner, payee, vendor, merchant, or beneficial-owner information before or during onboarding, activation, settlement, or continued use of an applicable Service.

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  • Legal name, business name, addresses, and contact details.
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  • Date of birth or date of formation, as applicable.
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  • Tax identification, registration, or business-identification details.
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  • Authorized representative details.
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  • Beneficial ownership information for legal entities.
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  • Purpose of the relationship and expected transaction profile.
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  • Documentary and non-documentary verification information.
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  • Ongoing profile updates and periodic refreshes.
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Refusal to provide reasonably requested compliance information may result in onboarding denial, delayed activation, restricted access, suspension, rejection of transactions, or termination of the affected relationship or workflow.

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7. Sanctions and Restricted-Party Screening

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Tilli may screen customers, partners, beneficial owners, payees, counterparties, transactions, or related data against sanctions lists, restricted-party lists, geolocation signals, negative news, or other compliance-relevant indicators. If Tilli identifies a potential match or elevated risk, Tilli may hold or reject transactions, restrict or suspend the affected workflow or account, request additional documentation, escalate the matter for manual review, or notify partners, processors, networks, or authorities where required or appropriate.

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8. Transaction Monitoring and Suspicious Activity Review

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For applicable Services, Tilli may use automated and manual controls to review activity for red flags, anomalies, suspicious behavior, fraud indicators, sanctions concerns, structuring, unusual velocity, account misuse, or other potentially unlawful or unauthorized activity.

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+ Monitoring may consider transaction amount, frequency, origin, destination, changes in risk profile, geographic inconsistency, unusual payment or disbursement activity, data mismatches, evasion patterns, or attempts to use Beacon, Nudge, tilliX, JAREIS, or other Tilli Services to initiate, mask, automate, or scale prohibited payment or onboarding activity. +
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9. Holds, Restrictions, and Service Controls

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Tilli may delay, reject, reverse where permissible, or otherwise restrict transactions, onboarding steps, activations, settlements, account changes, or automated CTAs when reasonably necessary for fraud prevention, sanctions screening, KYC or KYB review, suspicious-activity investigation, legal process response, partner or processor requirements, or safety, security, and reputation protection.

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10. Recordkeeping

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Tilli may maintain records relating to onboarding, verification, due diligence, screenings, investigations, compliance decisions, reports, and other AML or sanctions controls for periods reasonably necessary to comply with law, partner requirements, audit expectations, dispute needs, or internal risk-management requirements.

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11. Training

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Tilli may provide AML, sanctions, fraud, and financial-crime compliance training to relevant employees, contractors, and operators based on role and risk.

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12. Testing and Review

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Tilli may conduct periodic review, testing, validation, partner review, or independent assessment of applicable AML, sanctions, fraud, and onboarding controls. This policy should be reviewed at least annually and may be updated more frequently to reflect changes in law, risk, product design, banking or processor requirements, and operational experience.

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13. Confidentiality and Law-Enforcement Cooperation

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Compliance investigations, alerts, reports, and related records may be treated as confidential and restricted to those with a legitimate need to know. Tilli may cooperate with regulators, law enforcement, banking partners, processors, or other lawful authorities as required or appropriate.

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14. Customer and Partner Responsibilities

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Customers and partners using applicable Services must provide timely, accurate, and complete compliance information reasonably requested by Tilli, avoid using the Services to conceal, structure, facilitate, or automate unlawful financial activity, avoid routing activity through Beacon, Nudge, tilliX, JAREIS, or other Tilli tools in a manner intended to evade screening or monitoring, and comply with applicable law and product-specific compliance instructions.

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15. Contact and Escalation

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Email: legal@tilli.pro

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Mailing Address: 8260 Greensboro Dr, Suite 270, McLean, VA 22102, United States

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Redirecting to Tilli AML Policy.

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- ✨ See how much you could save with Tilli — calculate your ROI in 2 minutes. - -
+ ✨ See how much you could save with Tilli — calculate your ROI in 2 minutes. + +
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Anti-Slavery & Anti-Trafficking Policy

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Last Updated: January 2023

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1. Purpose

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- Tilli is committed to maintaining the highest ethical standards in all our business dealings. This policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains or in any part of our business. -

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Ethics Policy
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Tilli Consolidated Anti-Slavery and Anti-Trafficking Policy

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Last updated: May 11, 2026

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Tilli maintains a zero-tolerance approach to modern slavery, forced labor, human trafficking, unlawful child labor, and related exploitation in its operations, workforce, supply chain, and business relationships.

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+ United States operations + Utilli LLC (doing business as Tilli)
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2. Scope

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- This policy applies to all persons working for Tilli or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners. -

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- This policy applies to all our activities and operations globally, including but not limited to our offices in McLean, Virginia, and all international operations. -

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+ India operations + Tilli Software India Private Limited
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3. Our Commitment

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- We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We implement due diligence procedures for our supply chains and contractors to ensure compliance with this policy. -

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  • We conduct regular risk assessments to identify and address potential slavery and trafficking risks
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  • We maintain transparent supplier relationships and expect the same high standards from our contractors and suppliers
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  • We provide training to relevant employees to ensure understanding of modern slavery risks
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  • We maintain a zero-tolerance approach to modern slavery and human trafficking
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4. Procedures

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- To ensure compliance with this policy, we have implemented the following procedures: -

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4.1 Due Diligence

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  • Supplier audits and assessments
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  • Contractual obligations requiring compliance with anti-slavery laws
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  • Regular monitoring and review of supply chain practices
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1. Purpose

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This policy establishes Tilli's consolidated anti-slavery and anti-trafficking framework for global business operations and supports customer, partner, procurement, and government-contracting diligence.

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4.2 Reporting

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  • Clear reporting channels for concerns about modern slavery
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  • Protection for whistleblowers
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  • Investigation procedures for reported concerns
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2. Covered Entities

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For United States operations, the relevant entity is Utilli LLC (doing business as Tilli). For India operations, the relevant entity is Tilli Software India Private Limited. Those entities are referred to in this policy individually or collectively, as applicable, as Tilli or Tilli Software.

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3. Scope

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This policy applies to Tilli's directors, officers, employees, temporary workers, contractors, subcontractors, consultants, recruiters, suppliers, vendors, referral partners, other business partners, and other persons or entities acting for or on behalf of Tilli. It applies across Tilli's operations globally, including corporate, engineering, sales, implementation, support, operations, partner, vendor, and procurement functions.

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4.3 Training

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  • Regular training for procurement and HR staff
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  • Awareness programs for all employees
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  • Specific training for high-risk roles
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    4. Prohibited Conduct

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    Tilli prohibits conduct that constitutes or supports modern slavery, trafficking in persons, forced labor, coercive labor practices, unlawful child labor, or related exploitation.

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    • Trafficking in persons.
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    • Use of forced, bonded, indentured, or involuntary labor.
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    • Unlawful child labor.
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    • Procurement of commercial sex acts in connection with business activity.
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    • Confiscation, destruction, concealment, or denial of access to identity or immigration documents.
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    • Misleading or fraudulent recruiting practices.
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    • Charging prohibited recruitment fees to workers.
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    • Threats, coercion, intimidation, abuse, retaliation, or other exploitative practices.
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    • Knowingly engaging suppliers, recruiters, contractors, or partners that participate in such conduct without appropriate remediation or disengagement.
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5. Disciplinary Actions

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- Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organizations working on our behalf if they breach this policy. -

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5. Core Commitments

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Tilli is committed to maintaining ethical employment and sourcing practices, assessing and managing slavery and trafficking risks in relevant business relationships, using due diligence and contractual controls with relevant suppliers and partners, investigating credible concerns, protecting good-faith reporters from retaliation, and reviewing and updating this policy periodically.

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6. U.S. Government Policy

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- In accordance with U.S. Government policy, Tilli strictly prohibits: -

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6. Due Diligence and Supply Chain Controls

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Tilli may implement risk-based procedures such as supplier, contractor, recruiter, and partner due diligence; contract clauses requiring compliance with anti-slavery and anti-trafficking laws and this policy; review of labor and subcontracting practices; targeted assessments for higher-risk roles, geographies, or third-party relationships; and remediation plans, suspension, or termination where material concerns are identified.

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7. Reporting Concerns

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- If you have any concerns about modern slavery or human trafficking in relation to Tilli's operations or supply chains, please report them immediately to: -

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Compliance Officer

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Email: compliance@tilli.pro

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Phone: 1-888-TILLI-00

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Address: 8260 Greensboro Dr, Suite 270, McLean, VA 22102

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7. Reporting and Non-Retaliation

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Anyone covered by this policy must promptly report suspected violations, red flags, or concerns involving modern slavery, trafficking, forced labor, unlawful child labor, coercive recruiting, document confiscation, or related misconduct.

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+ Tilli will not tolerate retaliation against a person who raises a concern in good faith, participates in an investigation, or supports enforcement of this policy.
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8. Review and Updates

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- This policy will be reviewed annually and updated as necessary to ensure it remains current and effective. The Board of Directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations. -

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8. Investigations and Remediation

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Tilli may investigate reported or observed concerns and may request information, suspend onboarding or procurement, require corrective action plans or remediation, restrict or terminate supplier or partner relationships, or escalate matters to senior management, legal counsel, customers, prime contractors, or authorities where required or appropriate.

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9. Training and Awareness

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Tilli may provide role-based training or awareness activities to relevant personnel, especially those involved in procurement, vendor management, recruiting, human resources, partner management, operations, and government-contracting support.

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10. Compliance with Government and Legal Requirements

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Tilli intends to align this policy with applicable anti-slavery, anti-trafficking, labor, procurement, and government-contracting requirements relevant to its business relationships and operating regions. Where specific customer, partner, or government requirements apply, Tilli may maintain supplemental procedures or contractual obligations.

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11. Policy Review and Updates

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This policy should be reviewed at least annually and may be updated more frequently to reflect changes in law, risk, operations, sourcing, or customer and government expectations.

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12. Enforcement

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Failure to comply with this policy may result in disciplinary action, removal from an engagement, termination of employment or contract, suspension of business activity, or termination of supplier, recruiter, or partner relationships.

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13. Contact

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Email: legal@tilli.pro

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Mailing Address: 8260 Greensboro Dr, Suite 270, McLean, VA 22102, United States

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