AML Policy

AML Policy

Money Laundering is the process of disguising the origin of the proceeds of crime. Terrorist financing provides funds for terrorist activity. The use of products and services by money launderers and terrorists exposes the Company to significant criminal, regulatory and reputational risk.

This policy is designed to provide direction to staff on the approach and management of Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) within the Company. This policy supports management’s objective of mitigating the following risks:

  • Money laundering;
  • Terrorist financing;
  • Sanctions
  • Politically exposed persons (PEPs);
  • Legal and regulatory risk.

This policy applies to all individuals working at all levels within the Company, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term workers, casual and agency staff, all of whom are collectively referred to as ‘staff’ in this document.

The Company’s Compliance Head will provide direction to, and oversight of, the AML and CTF strategy as well as apply a risk-based approach across the business.

The Company will enforce a strict anti-money laundering policy with zero tolerance for money laundering or terrorist financing activities and ensure it knows who its customers are and also who it is going into business with. Such activity is more commonly known as due diligence / Know Your Customer (KYC) and Know Your Business (KYB). The Company has set out robust processes and procedures to help meet these requirements.

Money Laundering

There are three broad groups of offences related to money laundering that the Company must avoid committing.

These are:

  • knowingly assisting (in a number of specified ways) in concealing, or entering into arrangements for the acquisition, use, and/or possession of, criminal property;
  • failing to report knowledge, suspicion, or where there are reasonable grounds for knowing or suspecting, that another person is engaged in money laundering or terrorist financing; and tipping off, or prejudicing an investigation.

Staff will be trained in AML awareness and how to spot potentially suspicious activity (refer to the Company’s Reporting Suspicious Activity Policy).

Terrorist Financing

There can be considerable similarities between the movement of terrorist property and the laundering of criminal property: some terrorist groups are known to have well established links with organised criminal activity. However, there are two major differences between terrorist property and criminal property.

More generally:

  • often only small amounts are required to commit individual terrorist acts, thus increasing the difficulty of tracking the terrorist property;
  • terrorists can be funded from legitimately obtained income, including charitable donations, and it is extremely difficult to identify the stage at which legitimate funds become terrorist property.

The Company will ensure its staff are well versed in AML awareness and the underlying policies and procedures allowing the Company to demonstrate compliance with applicable rules and regulations in this aspect.

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