1.1. The Company upholds its integrity of observing regulations under the Anti-Money Laundering (AML)/Terrorism Financing (TF) compliance. The intention of this policy is to filter illegal activities including securities fraud, terrorist financing, and other unlawful acts in relation to concealing the origin of illegally obtained money.
Money Laundering means:
a. the conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s action;
b. the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such activity;
c. .the acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such activity;
d. participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (a), (b) and (c). Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country
Terrorism financing means: the provision or collection of funds, by any means, directly or indirectly, with the intention that they are used or in the knowledge that they are to be used, in full or in part, in order to carry out any terrorist act.
1.2. In compliance with the Anti Money Laundering Act 2006 (as amended), Anti Money Laundering Regulations 2012 and Guidelines on Anti-Money Laundering and Combating the Financing of Terrorism Procedures for Reporting Entities in Seychelles, the Company conducts authentication and verification procedures for the Client’s identification. The Client must provide particular documents accordingly to complete the procedure and in compliance with the policy. The Company keeps record of the Client’s documents and transactions for security purposes.
2. Policy Scope
2.1. The Clients, executives and employees of the Company hereby act in accordance with the Anti-Money Laundering policy of the Company, wherein necessary documents must be provided and completed accordingly.
2.2. All transactions performed through the Company’s official website and/or through the corresponding banks and financial institutions are correlatively documented and recorded for security purposes. In accordance with the AML Policy, the MLRO executes Suspicious Activity Reports (or SARs) and other mandatory disclosure in writing to the Financial Services Authority (Seychelles) and to the Financial Intelligence Unit.
2.3. The Company and its workforce commit to the prevention of money laundering and all other unlawful activities. The business division of the Company undergoes risk-based methods judiciously estimated to filter and identify the foregoing reporting and/or writing under the International Anti-Money Laundering Acts, Regulations and Guidelines.
3.1. The Company is unwavering to its public responsibility to avert illegal misconducts. The Company and its workforce strictly observe the verification practices and is strictly vigilant to further prevent and control risks that can affect the Company’s operations. The legal framework on which the company’s AML and Customer Due Diligence procedures are founded are the Seychelles AML Act 2006 (as Amended) , Seychelles AML Regulations 2012 and Guidelines on Anti-Money Laundering and Combating the Financing of Terrorism Procedures for Reporting Entities in Seychelles
3.2. The Company will always be informed about any national and global occurrence on initiatives to further prevent terrorism funding, money laundering, tax evasion, and other legal financing activities. The Company justifies the protection of its managerial operations, personal records of employees and the Clients, and all forms of documents confidential in nature. Any form of threat in relation to illegal financing activities will deal with legal proceedings.
4. Customer Due Diligence
4.1. For the purpose of mitigating any Money Laundering risks, the company applies strict Customer Due Diligence; information that comprises of facts about clients, which should enable an organisation to assess the extent to which the client exposes it to a range of risks. These risks included money laundering and terrorist financing. Customer Due Diligence (CDD) procedures applies during the on-boarding of a client and but also an on-going review. The policies aims at allowing the company to know the client and entities it deals with but also the Ultimate Beneficial Owners (UBOs) and Authorised Signatories as appropriate. Special safeguards are also implemented for business relationships with politically exposed persons (PEPs) and clients from countries or industries deemed high risk.
4.2. If the Client provides false information, he/she will receive a respective penalty and/or injunction, and if the provided information is proven to be in relation to money-laundering activities, the Company reserves the right to reject the information.
4.3. Identity verification includes but is not limited to the provision of the Client’s complete name and address, date of birth, passport number and country of issuance, and other personal information that the Company may request for.
4.4. The Client is responsible for providing true and accurate information that should be recorded data. The Company reserves the right to reject, cancel, and/ or suspend any transaction if any form of information discrepancy occurs. Transactions by third parties in lieu of the Client need a power of attorney (POA) which will be subject for approval by the Company. If the third-party transaction is not approved, the Company reserves the right to consider the transaction invalid without providing an explanation.
5. Suspicious Transactions Reporting
5.1 In its internal procedures, the company describes in precise terms, for the attention of its working members, when it is necessary to report and how to proceed with such reporting. Reports of atypical transactions are analyzed within the AML team in accordance with the precise methodology fully described in the internal procedures. Depending on the result of this examination and on the basis of the information gathered, the AML team will:
- decide whether it is necessary or not to send a report.
- decide whether or not it is necessary to terminate the business relations with the client.