(to be referred as “Company”)
- Scope of the policy
This AML policy applies to all the Companies’ officers, employees, appointed producers and products and services offered by the Company. All business units and locations within the Company will cooperate to create a cohesive effort in the fight against money laundering. Each business unit and location has implemented risk-based procedures reasonably expected to prevent, detect and cause the reporting of transactions. The Company has appointed an AML Compliance Officer (referred to as “the AML Officer”). The AML Officer is responsible for initiating Suspicious Activity Reports (“SARs”) or other required reporting to the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Officer.
2. Policy
The Company takes all measures to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. The Company is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.
“Money laundering” is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages, placement, layering and integration.
“Terrorist financing” an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.
3. Customer identification program
The Company has in place Customer Identification Procedures. The Company will provide notice that they will seek identification information; collect certain minimum customer identification information from each customer, record such information and the verification methods and results;
4. Required customer information.
In compliance with the applicable Legislation, we will ask for certain minimum identification information from each customer which opens an account with the Company.
This minimum information may include:
- Full name;
- Date of birth;
- Country of birth;
- Gender;
- Citizenship;
- Email address;
- Phone number;
- Identity document information;
- Residential address.
The Company will request from customers relevant documentation to verify the above information.
Upon establishing a relationship with a legal entity, the following information shall be collected and verified:
- Full legal and trade name;
- Company number
- Legal form
- Legal status
- Legal address
- Controlling persons and their legal capacity
- Authorised representatives (other than controlling persons) and their legal capacity
- Shareholders and ultimate beneficial owners (UBO);
- Purpose of account
- Expected activity on the platform
- Source of entity’s funds;
- Other information which may be required for conducting identification and verification of the legal entity.
The Company applies enhanced due diligence measures for clients considered to be high risk. Therefore, we might request from you additional information and/or documentation.
5. Verifying information
The Company verifies the correctness of the data specified above using information originating from a credible and independent source for that purpose. For verification purposes, the Company shall rely on a government-issued identification to establish a customer’s identity. The Company, however, will analyze the information provided to determine if there are any logical inconsistencies in the information obtained. The Company will document its verification, including all identifying information provided by the customer, the methods used and results of the verification, including but not limited to sign-off by the appointed producer of matching photo identification.
6. Risk Based Approach
When the Company identifies any potential risks to money laundering and/or terrorist financing, it takes into account customer risk factors, countries and geographical areas, products, services and transactions risk factors, as well as any risk factors related to the delivery channels. However, these factors are not exhaustive, and the Company will take a holistic view of the risk associated with each situation.
7. Monitoring and reporting
The Company has in place measures and procedures for the appropriate monitoring of transactions. The Company considers the constant monitoring of the Clients’ accounts and transactions, an imperative element in the effective controlling of the money laundering and terrorist financing risks. To this end, the Company’s procedures and intensity of monitoring Clients’ accounts and examining transactions on the Client’s level of risk include the following:
a) the identification and investigation of:
- transactions which, as of their nature, may be associated with money laundering or terrorist financing.
- unusual or suspicious transactions which are inconsistent with the economic profile of the Client for the purposes of further investigation.
b) in case of any unusual or suspicious transactions, the person to whom it came to his attention, shall be responsible to communicate with the AML Officer in this respect.
c) the results of the investigations will be recorded in a separate memo and kept in the file of the relevant Clients, as applicable
d) the ascertainment of the source and origin of the funds credited to accounts.
e) the use of appropriate IT systems
The Company will continuously monitoring the customers transactions and overall behavior while they are using the Company’s services. The Company also put its best efforts to ensure that any information provided by the Client is up to date, so we it might request from clients occasionally to update their personal data during the course of business relationship with the Company. The Company may take an appropriate action such as suspending clients account or transaction for further investigation if the Company consider it necessary in order to protect clients and the Company from any potential illegal activity.
The Company reserves the right to cancel or deny a transaction at any point if there are suspicions regarding its legality.
8. Suspicious activity
There are signs of suspicious activity of money laundering. These are commonly referred to as “red flags”. Annex “A” gives examples of red flags.
If a red flag is detected, additional due diligence will be performed before proceeding with the transaction. If a reasonable explanation is not determined, the suspicious activity shall be reported to the AML Officer of the Company.
Upon notification to the AML officer of the Company, an investigation will be commenced to determine if a report should be made to appropriate law enforcement or regulatory agencies. The investigation will include, but not necessarily be limited to, review of all available information, such as payment history, birth dates, and address. If the results of the investigation warrant, a recommendation will be made to the AML Officer. to file a blocked assets and/or a SAR with the appropriate law enforcement or regulatory agency. The AML Officer is responsible for any notice or filing with law enforcement or regulatory agency.
Investigation results will not be disclosed or discussed with anyone other than those who have a legitimate need to know. Under no circumstances shall any officer, employee or appointed agent disclose or discuss any AML concern, investigation, notice or SAR filing with the person or persons subject of such, or any other person, including members of the officer’s, employee’s or appointed agent’s family.
A) Record Keeping
The Company will store your personal data collected for the purpose of establishing business relationship with you for minimum period of 5 years from the date of terminating your business relationship with the Company.
You may find additional information on collection and storage of your personal data in the Company’s Privacy Policy.
By applying for an account with us you agree to promptly provide us with all the information that we reasonably request in order to comply with all applicable laws and regulations relating to anti-money laundering.
If you have more questions, please contact us at:______________________
ANNEX “A”
Examples of red flags are:
- The customer exhibits unusual concern regarding the firm’s compliance with government reporting requirements and the firm’s AML policies, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.
- The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer’s stated business strategy.
- The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
- Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
- The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
- The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
- The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.
- The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.
- The customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents, or asks for exemptions from the firm’s policies relating to the deposit of cash and cash equivalents.
- The customer engages in transactions involving cash or cash equivalents or other monetary instruments that appear to be structured to avoid the $10,000 government reporting requirements, especially if the cash or monetary instruments are in an amount just below reporting or recording thresholds.
- For no apparent reason, the customer has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
- The customer is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force.
- The customer’s account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity.
- The customer’s account shows numerous currency or cashiers check transactions aggregating to significant sums.
- The customer’s account has a large number of wire transfers to unrelated third parties inconsistent with the customer’s legitimate business purpose.
- The customer’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a bank secrecy haven.
- The customer’s account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose.
- The customer makes a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.
- The customer makes a funds deposit for the purpose of purchasing a long-term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account.
- The customer engages in excessive journal entries between unrelated accounts without any apparent business purpose.
- The customer requests that a transaction be processed in such a manner to avoid the firm’s normal documentation requirements.
- The customer, for no apparent reason or in conjunction with other red flags, engages in transactions involving certain types of securities, such as penny stocks, and bearer bonds, which although legitimate, have been used in connection with fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the customer’s activity.)
- The customer’s account shows an unexplained high level of account activity with very low levels of securities transactions.
- Attempt to borrow maximum cash value of a single premium policy soon after purchase.
