Our Anti-Money Laundering Policy ("AML Policy") sets out the processes and controls to help us prevent, identify, manage and mitigate risks of us being involved in any kind of illegal activity, particularly money laundering.
Money laundering is the process of hiding or disguising the source of illegally obtained (dirty) funds to make them appear legitimate (clean), for example, by filtering the money through the financial system. Companies that offer financial services, like ours, are specifically targeted by criminals.
In response to the scale and effect of money laundering, local and international laws have been designed to combat money laundering and terrorism financing.
We have adequate controls and procedures to ensure we know with whom we are conducting business, commonly referred to as Know Your Customer (KYC), including Enhanced Due Diligence (EDD) measures for customers deemed as higher risk, for example Politically Exposed Persons (PEPs).
We analyze data and transactional patterns as a risk assessment and suspicion detection tool.
We have appointed a MLRO with a sufficient level of seniority, who has responsibility for oversight of compliance with the relevant legislation, regulations, rules, and industry guidance.
We have adopted a risk-based approach to combating money laundering and terrorist financing. We achieve this by accurately measuring our risk profile, balancing it with the need to optimize financial growth opportunities, and implementing processes and controls according to identified risks. This allows us to allocate resources in the most efficient ways.
We maintain and keep appropriate records for legally prescribed periods.
We report suspicious activity to the relevant law enforcement authorities in all jurisdictions we operate.
We screen against the United Nations, European Union, UK Treasury, and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions we operate.
We screen all employees and conduct additional background checks on entrusted employees. We provide training for all relevant employees on an ongoing basis.
For questions regarding our AML Policy or to report suspicious activity:
Information for legal authorities and law enforcement is available upon request.
Last updated: November 2024