Anti-Money Laundering/Counter the Financing of Terrorism (AML/CFT) Policy
The IMBA AML Policy is designed to prevent money laundering, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
- Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
- Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
- Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- The maintenance of appropriate records for the minimum prescribed periods;
- Training and awareness for all relevant employees
Counter Financing of Terrorism (CFT)
The Company takes a risk-based approach when adopting and implementing counter financing of terrorism (CFT) measures and in conducting AML risk assessments.
The company adopted internal CFT controls and make undefended decisions regarding CFT matters supersedes any business, strategic or other operating task.
International Sanctions Policy (ISP)
Our company is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists.
Know Your Customer Procedures (KYC)
Individuals can be identified by passport or other identification document and utility bills stating their current post address. Companies have to be identified by extracts from the Chamber of Commerce or by notary deed. Copies have to be made and archived in files securely.