AML Policy

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AML Policy 

About this Privacy Statement:

The purpose of the AML policy is to ensure that Company complies with the obligations and requirements set out by United Kingdom legislation, regulations and rules regarding the prevention, identification and reporting of money laundering or terrorism financing.

We have robust and effective Risk assessment and due diligence measures and controls in place to ensure compliance with regulations, laws and standards and ensure a continuous practice of business relationship monitoring and staff training for an inclusive approach.

Scope:

The policy relates to the below parties:

  • Our permanent, fixed term, and temporary staff
  • Any third-party representatives or sub-contractors
  • Agency workers
  • Volunteers
  • Interns and agents engaged with Company in UK or overseas
  • Clients using our service

Failure of any parties to adhere to the guidance and objectives laid out in this policy, may lead to disciplinary action.

Regulations:

We advocate continued compliance with the guidance and rules laid out in the following legislation:

  • The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017;
  • The Criminal Finances Act 2017;
  • The Proceeds of Crime Act 2002 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2015);
  • The Money Laundering Regulations 2007 (SI 2007 No. 2157);
  • The Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001, the Terrorism Act 2006 and the Terrorism Act 2000 and Proceeds of Crime Act 2002 (Amendment) Regulations 2007).

How to implement AML

We adhere to and comply with the principles of KYC and due diligence, established by applicable legislation with aim to prevent money laundering and terrorism financing. We take a Risk-based approach and perform strict due diligence checks and ongoing monitoring of all clients and their transactions.

As per AML/CFT legislation, we utilizes 3 levels of due diligence checks, dependent on the risk, transactions and customer:

  • CDD – Customer Due Diligence is the standard due diligence procedure used in most cases for verification and identification.
  • EDD – Enhanced Due Diligence is used for high-Risk customers, large transactions or specialised instances such as PEP’s or those from the FATF and other high-Risk countries.
  • Additional checks – for certain business relationships on top of standard EDD measures. Mostly applicable to maritime industry.

Every single transaction is routed through the rule-based Transaction Monitoring Module which uses omnichannel paradigm to analyse and cross-match data obtained through different channels at once. The module evaluates every transaction (including peer to peer transactions) based on AML/CFT and anti-fraud rules.

We keep track of client information for ongoing monitoring of business relationships.  Some of the measures include, but are not limited to keeping track of identification documents, power of attorney and other document expiry dates, sending out due diligence questionnaires, investigating the reason behind unusually large and/or complex transactions etc.

Client behaviour is analyzed with the help of an automated, self-learning algorithm, which identifies and reports to compliance staff abnormalities in client behaviour, spending patterns, location and other patterns.

Prohibited Countries&Products:

We deny to companies residing or establishing in “prohibited” countries, as well as restricts certain transactions with:

  • Countries which are identified by a credible source as lacking AML/CFT controls;
  • Countries under sanctions or embargos issued by, for example OFSI, UN, EU or OFAC;
  • Countries which have significant level of corruption, tax evasion, drug production or other relevant criminal activity;
  • Countries which are identified by a credible source as providing funding or support to terrorism;
  • High intensity drug-trafficking areas.

We cannot provide service for businesses that sell the following goods or services:

  • MLM (without a tangible product)
  • Adult and Pornographic Content
  • Animals
  • Alcohol
  • Body Parts
  • Child Pornography
  • Cyberlocker Services
  • Drugs
  • eWallets
  • File-Sharing Services
  • Money Transfer Businesses
  • Money Transmission
  • Online gaming or Gambling in the USA (USA Cards must be blocked 7995 MCC)
  • Pharmacy: Controlled Substances
  • Prostitution
  • Tech Support
  • Telemarketing
  • Tobacco (when sent outside of your country and/or state)
  • Weapons

Any actual or suspected acts of money laundering and terrorism financing will be reported to the National Crime Agency (NCA) as applicable by Money Laundering Reporting Officer (MLRO) who is appointed to oversee all aspects of the AML/CFT functions.