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Anti-money laundering and countering terrorist financing manual (AMLCTF)

Updated over a month ago

What is money laundering?

The expression "money laundering" covers all activities that conceal and disconnect the origins of criminal proceeds from the criminal, so that they appear to have originated from a legitimate source.

Two main indicators of Money Laundering are:

  • An arrangement or transaction between two or more parties involving property which has been acquired criminally or by the proceeds of crime.

  • Suspicion or knowledge that property has been acquired criminally or by the proceeds of crime.

The intended purpose of the transaction is:

  • To conceal the true ownership and origin of criminal proceeds.

  • To maintain control over them.

  • To change their form.

Individual transactions may only be a small part of a bigger picture:

What is financing of terrorism?

For terrorists, the acquisition of funds is not an end in itself but a means of committing a terrorist attack. With terrorist financing, it does not matter whether the transmitted funds come from a legal or illegal source as terrorist financing frequently involves funds that, prior to being remitted, do not necessarily derive from criminal activity.

Tracking terrorist financial transactions arising from legitimate sources is more difficult than following the money trails of the proceeds of crime because of the relatively small amounts of funds required for terrorist actions and the range of legitimate sources and uses of funds. Terrorist attacks are in many cases comparatively inexpensive, and their financing is often overshadowed by the larger financial resources allocated for the group’s political and social activities, making it more difficult to uncover the illicit connections.

Identifying and disrupting the mechanisms through which terrorism is financed are key elements in the overall efforts to combat terrorism. As well as reducing the financial flows to terrorists and disrupting their activities, action to counter terrorist financing can provide vital information on terrorists and their networks, which in turn improves law enforcement agencies’ ability to undertake successful investigations.

The Company can assist governments and their agencies in the fight against terrorism through prevention, detection and information sharing. The Company seeks to prevent terrorist organizations from accessing the funds that they administer, assist governments in their efforts to detect suspected terrorist financing and promptly respond to governmental enquiries.

Recognising the difficulties inherent in identifying financial transactions linked to the financing of terrorism (many of which appear routine in relation to information known at the time) we have implemented monitoring procedures for identifying and reporting unusual or suspicious transactions which may assist governmental agencies by linking seemingly unrelated activity to the financing of terrorism.

Our Commitment

  • The proper verification of the identity of clients.

  • Exercising increased monitoring of clients identified as high risk.

  • Monitoring for unusual transactions.

  • Ongoing monitoring of clients against lists generated by competent authorities of known or suspected terrorists or terrorist organisations.

This procedure outlines our policy that guard against:

  • Our platform being used for money laundering or financing terrorism.

  • The committing of an offence under the relevant laws by our company itself or its employees.

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