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PART I : DEFINITIONS, POLICY STATEMENT AND INTRODUCTION
Definitions and interpretations
The policy of the Company is:
The Company commits to implementing all required policies and processes to prevent money laundering and to complying with all applicable laws in this respect.
Regulations to Prevent Money Laundering.
For each “regulated activity,” there are five mandatory anti-money-laundering regulations. The Company would be wise to think about using this method while trying to figure out how to mitigate the threat of money laundering.
General and Specific Provisions.
If any of the following violations are brought to light, the Business and its employees face criminal liability. The several types of money laundering offences include:
Protecting the privacy of our clients is of the utmost importance to us.
It is essential to underline that sharing your concerns about money laundering does not compromise client confidentiality.
The duties of the Board of Directors
The duties of the Board in relation to the prevention of money laundering and terrorist financing include the following:
Money Laundering Reporting Officer (or MLRO)
The Compliance officer oversees all money laundering compliance and reporting issues. The Compliance Officer will first serve as the Money Laundering Reporting Officer (herewith – MLRO). The MLRO will oversee ensuring compliance with the government requirements on anti-money laundering systems and controls. The MLRO will have adequate authority and independence, as well as access to resources and information, to carry out that task. If the Company decides to separate the Compliance Officer’s responsibilities from those of the Money Laundering Reporting Officer, this document will be updated accordingly.
The MLRO’s responsibilities are:
Compliance with the Company’s anti-money laundering measures is critical. Failure to comply may not only constitute a criminal offense and call into question whether the Company and the person in question are fit and proper to undertake the business for which the Company has been licensed. Individuals who fail to follow the money laundering procedures outlined in this manual may face summary dismissal.
The Compliance Officer will be responsible for ensuring that the Company’s anti-money laundering policies and procedures are followed. The Compliance Officer will be specifically accountable for:
PART 3: PROCEDURES AND OBLIGATIONS OF THE COMPANY
Duty on establishing business relationships.
The Company is not permitted to engage in a one-time transaction or establish a commercial link during the applicable financial activity unless:
As soon as practically feasible after the first interaction, and in any case before transferring or paying out any money to a third party, the Company must ensure that adequate proof of the identity of any client or counterparty is supplied, or such other precautions are implemented. If a customer seems to be acting on behalf of someone else, they must also provide sufficient proof of the other party’s identity in order to pass the identification check.
If the company is not presented with sufficient documentation, it will cease doing business with the customer and will cancel any contracts that have been made, unless the company has already notified the proper authorities. Any suspicion or actual knowledge of money laundering must be reported to the MLRO without delay.
Methods of Identification
The Company will take precautions to verify that it is communicating with a legitimate individual or corporation and will gather sufficient proof to support the applicant’s claims of being the person or entity claimed in the application. Company has the ultimate legal duty for ensuring that the techniques and evidence collected are adequate when relying on a third party to verify or confirm the identity of an application.
There is no one piece of documentation or data source (outside of a database constructed from a number of other valid data sources) that can be relied upon to verify both name and permanent address, hence the identification process must be cumulative.
The Company will take all necessary actions to verify the identity of its customers and, if relevant, their beneficial owners in line with applicable law and regulatory authority regulations.
For all customer types, it is essential to collect and maintain the following details, in addition to identity information (as described below):
The Company will be satisfied with the identity after reviewing government-issued identification papers or other suitable evidence. Full name, DOB, nationality, and residence address will all be collected as part of the identification process. All forms of identification presented at the door must be up to date.
No special steps beyond the usual commercial checks and due diligence are usually necessary if the applicant company is listed on a recognized or approved stock exchange, or if there is independent evidence that the applicant is a wholly owned subsidiary or subsidiary under the control of such a company.
If the application is an unlisted business, further steps will be taken to confirm the company’s identity, good standing, and the authorization of persons acting on its behalf. Although the specific paperwork needed in these situations might vary from jurisdiction to jurisdiction, it will often consist of:
Beneficial Owners Due diligence must be done on all principal owners identified in accordance with the following principles:
While clear scanned versions of documents will be accepted, attested scanned copies or genuine attested copies may be requested if further clarification is required.
The Company may use an online version of a document relating to the corporate entity (such as an extract from the Commerce Register) if it is available on the official website of the relevant state authority, so long as a printout of the document is made by a member of the Company’s staff and filed away in the appropriate client file.
Contact details such as a phone number and email address will also be sought from our customers.
High- risk countries.
higher level of scrutiny will be applied to clients and beneficial owners living in, and funds originating from, countries that have been identified by credible sources as having insufficient anti-money laundering standards or as posing a substantial risk for crime and corruption. The Company will be more cautious about doing business with customers or beneficial owners located in such nations.
Foreign Countries and Territories referred to as “Offshore Jurisdictions”.
The risks associated with offshore entities are included into the due diligence procedures detailed here. But for business performed by customers or beneficial owners located in certain places, the Company will impose further limits.
High Risk Activities.
There will be a heightened level of scrutiny placed on clients and beneficial owners whose funds originate from suspicious or high-risk activities for money laundering.
Officials of the state.
More attention will be paid to the personal lives of those in positions of public trust, such as elected officials, senior executives of government businesses, lawmakers, political party leaders, and others like them.
Accountability for Confirmation.
A key responsibility of the MLRO while onboarding a new client is verifying the identity of each individual. A customer agreement should not be given to a new applicant until all verification processes have been completed and sufficient identification has been supplied (as determined in writing by the Compliance Officer).
Procedures for Verification.
Clients must be checked and evaluated using the “Client Profiling” form, and the process must be documented by noting the relevant details on the Company’s documentation checklist as required by Section 3.2.
The stamp of approval from the Compliance Officer.
As soon as the employee or the Company’s designee has finished filling out the Client Identification Questionnaire, it should be signed and sent to the Compliance Officer for filing. Each applicant’s documents need to be countersigned by the Compliance Officer, who is also in charge of deciding what, if any, extra information or paperwork is needed to start doing business with the applicant.
Methods for maintaining a record of events.
In addition, the Company must keep all documentation for at least 5 years after the deal closes. Documentation of transactions with or for this customer, as well as documentation of the counterparty’s identity, should be kept.
Education and training.
The following will be communicated to employees who handle or are in charge of handling transactions that may involve money laundering:
As part of this process, the Compliance Officer should provide presentations. It is imperative that employees keep their knowledge of the Anti-Money Laundering, Anti-Terrorism Financing, And Proceeds of Unlawful Act, the Guidelines on Anti-Money Laundering and Counter Financing of Terrorism and Other Business, and the Regulations up to date due to the severe consequences of violating these laws.
The dates, content, and names of people who have attended anti-money-laundering training should all be documented and maintained on file.
Obligation to report.
Any employee who has knowledge, suspicion, or reasonable grounds to suspect money laundering must report such information in accordance with applicable law and regulation. Consequently, a worker is in violation of the law even if he or she does not know or suspect anything but should have known or suspected something and did not disclose it. Getting there will need constant monitoring for suspicious purchases. The Company’s understanding of its customers is its first and best line of defense against and indicator of money laundering operations. Verifying the identities of new counterparties and making sure they are real businesses that adhere to the same ethical standards as the Company are both very important.
In the past, knowing about money laundering might include knowing about conditions that would suggest facts to such an honest and reasonable person or bring them into doubt, as well as knowing about the obvious and willfully disregarding them.
Suspicion is more than just a hunch, yet it’s judged on an individual basis.
The concept of “reasonable grounds to suspect” adds an objective test of suspicion as opposed to a subjective one. This may be the result of willful ignorance (ignoring obvious evidence) or carelessness (not doing essential research) or a failure to properly evaluate the information at hand.
Therefore, the Company will ensure that its staff takes all appropriate measures under the circumstances to learn about the customer and the motivation behind the transaction or instruction.
Money Movements That Raise Red Flags
In general, a suspicious transaction is one that doesn’t fit with the customer’s established pattern of lawful activity. Therefore, we’ll be paying special attention to the specifics of the client’s business and needs. Any employee who has any information about or suspicions of money laundering is required to report it.
Whether or not a transaction is suspicious may be determined with the use of the following questions:
Consider if the client’s preferred mode of payment fits the norm: No matter how little, every suspicion of money laundering should be dealt with in the absence of the MLRO. An in-house report form for reporting money-laundering concerns is available to the employees.
The MLRO’s duty is to inform the proper authorities whenever a report of knowledge or suspicion is made.
It is important to keep an eye on any and all accounts associated with customers who hold positions of public trust, such as government officials and politicians.
It is possible to defend yourself against a claim of breach of confidence by stating that you reported a suspect. However, the MLRO or his deputy must approve any statements made to the media. In a similar vein, he or his delegate should be contacted with any requests for clarification or further information. Confidentiality is of the highest importance throughout an investigation, and employees are reminded that “tipping off” is a crime.
Employees are obligated to report any suspected instances of money laundering to the MLRO. There has to be a complete record of the suspicious activity, including the identity and location of the employee who reported it, complete client and account information, and a detailed explanation of what happened.
It is important to keep track of any questions asked about the report internally, as well as the rationale for submitting or rejecting the report.
The MLRO must stress the need of keeping information about a report confidential and warn the reporting employee not to “tip off” the subject of the reported suspicion.
If the company or transaction was terminated due of red flags related to the application or proposal, then you must report this information.
The MLRO, or his duly authorized delegate, will look into the matter, and if reasonable suspicion is raised, it will be reported.
The MLRO or his or her delegate will not need anyone else’s help or permission before releasing any report.
In making this determination, the MLRO will have access to any relevant information, including “know your business information,” that is in the Company’s possession. Information regarding a client’s or any person for whom the client has been or is acting financially; and the nature of any transactions the Company has engaged into with or for the client would be considered “know your business information.”