ANTI-MONEY LAUNDERING POLICY
This policy is to set out the basis of standards for compliance with the principles and obligations as per the Anti-money laundering and Counter Terrorism Financing legislative international and domestic requirements (hereinafter referred to as Regulations"). References in this Policy to money laundering should also be interpreted as references to terrorist financing.
Complying with the Regulations is an on-going obligation to maintain policies and procedures which are intended to combat money laundering. This Policy and the relevant internal procedures should be properly supported by management controls, kept up to date and communicated to staff. The Company should adopt a risk based approach, varying the measures taken in light of the assessed risk of money laundering.
Key to the prevention of money laundering is:
SUPPORTING POLICIES AND CONTROLS
Internal Policies and Procedures
The Company should maintain internal policies and procedures for:
The Company's policies and procedures should take a risk based approach. The Company's policies and procedures must:
The senior managers of the Company are responsible for ensuring that the Company’s policies and procedures are put in place and applied effectively so as to ensure proper assessment and management of the money laundering risks to the company.
The Company's policies and procedures must also nominate an individual to:
‘Knowledge’ means knowledge of money laundering activity based on information which came to a member of staff or the Nominated Officer in the course of the business of the Company.
‘Suspicion’ means an opinion based on information or circumstances but without any certainty or proof.
Controls and Communications
The Company must ensure that internal management controls are put into place in order to be aware of potential money laundering.
Internal controls should include:
The Company should regularly assess its policies, procedures and management controls to ensure the risks of money laundering continue to be known and managed.
RISK BASED APPROACH
A risk based approach is an approach which is a cost effective and proportionate way to manage the risk of money laundering. In implementing a risk based approach, the Company should consider: the risk posed by the customer.
The following customers and behavior should be considered riskier:
1. European Union Consolidated List 2. European Union Terrorist List 3. Financial Action Task Force Non-Cooperative Countries and Terrorists 4. Her Majesty’s Treasury – also known as Bank of England (Consolidated List) 5. Her Majesty’s Treasury (Investment Ban List) 6. Interpol List of Most Wanted – Recent Event Red Alerts 7. US Treasury Office of Foreign Assets Control (OFAC) Specially Designated Nationals 8. US Treasury Office of Foreign Assets Control (OFAC) Sanctioned Countries 9. US Department of State Foreign Terrorist Exclusion List 10. United Nations Sanction List.
The Company should monitor the risk of money laundering by being aware of patterns of business transactions, including:
Risk based control procedures include:
CUSTOMER DUE DILIGENCE, IDENTIFICATION AND MONITORING
Customer Due Diligence
The object of customer due diligence is to identify customers and verify their identity.
Customer due diligence should include checking the list of financial sanctions targets listed on the competent authorities website. The Company should not do business with a person or entity subject of a financial sanctions.
The Company should be able to demonstrate that its due diligence (KYC) measures are appropriate in light of the Company’s risk of money laundering by. Steps in the Know Your Customer (KYC) process are:
The business relationship should be continually monitored for trigger events which may create a requirement for further due diligence in the future.
The standard due diligence procedure requires customers’ identification as well as verifying of the customer’s identity . In addition, the Company ensures gathering of information so as to understand the nature of the business relationship with the customer. This due diligence procedure should give us confidence that we know who our customers are and that our services or products are s not being used for money laundering or for any other criminal activity.
As with simplified due diligence we monitor our customers throughout all the business relationship, which enables us highlighting any potential trigger events that may result in further due diligence being required.
What the enhanced due diligence actually entails will dependant on the nature and severity of the risk. The Company’s additional due diligence could take many forms - from gathering additional information to verifying the customers identity or source of income or perhaps an adverse media check. The checks should be relative and proportionate to the level of risk identified and should give confidence that any risk has been mitigated and that the risk is unlikely to crystallize
The Company asks its customers to state whether or not they hold or have previously held a prominent public government function and ensure that such customers are treated as high risk.
Identification and Verification
Identification can be documentary, electronic or a combination of both. A record should be kept of all evidence taken to establish the customer’s identity. Documentation of identity should be supplemented with additional identification such as a recent utility bill or a bank statement which is less than 3 months' old and which shows the customer's name and address.
The Company should monitor customer activity on an ongoing basis.
Ongoing monitoring includes:
Monitoring may take place as part of a review of previous transactions and can be manual or automated. Staff should be trained in conducting ongoing monitoring.
Sufficient records should be kept to demonstrate compliance with the Regulations, including records of:
Records should be kept during the business relationship and further for 5 years as from , the date the relationship with the customer ends.
Under no circumstances the COMPANY, its employees, consultants, or representatives will engage in negotiation with terrorists. Suspicious behavior or actions will be immediately reported to competent authorities.
The COMPANY, under the protection of the safe harbor from liability, may voluntarily receive or otherwise share information with any of the other financial or governmental institution regarding individuals, entities or other organizations for purposes of identifying and where appropriate reporting activities that may involve possible terrorist or money laundering activities.
All employees and agents have been provided with a copy of the present policy. All new employees and agents will be provided with a copy of this policy at the time of their hiring.
We appreciate your understanding and full cooperation in relation to the implementation of this policy.
The present policy has been approved by the Management on 13.12. 2016.
All enquiries regarding this policy shall be directed to the Legal and Compliance Department