Definitions
Money Laundering (ML): Means the process by which criminals attempt to conceal the origin and/or illegitimate ownership of property and assets that are the proceeds of criminal activities.
Terrorism Financing: Includes both legitimate and illegitimate money characterized by concealment of the origin or intended criminal use of the funds.
Know Your Customer/Business (KYC/B): This entails obtaining and verifying customer identity, preservation of records of customers, and mandatory disclosure of transactions to authorized statutory bodies.
Financial Intelligence Unit (FIU): The Global Financial Intelligence Unit, or equivalents in local jurisdictions.
Politically Exposed Persons (PEPs): Individuals who are or have been entrusted with prominent public functions in any country; generally present a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.
Enterprise Risk Management (ERM): Includes the methods and processes used by organizations to manage risks and seize opportunities related to the achievement of their objectives.
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Client: Includes any individual or entity with a business relationship with the Company or any individual or entity connected with a financial transaction that can pose a significant reputation or other risks to the Company
policy mandate
The Anti-ML & Combating the Financing of Terrorism Policy (“AML/CFT Policy”) sets out the guidelines for Pay4Me Integrated Technology. (herein referred to as ‘the Company’) compliance with AML/CFT obligations under the law, as well as regulatory directives, and prevents any transaction that facilitates criminal activities
policy description
ML and financing terrorism are financial crimes with economic effects. This policy is to eradicate the adverse effects of criminal economic activity and promote integrity and stability in financial markets. Compliance with this policy is also critical to preserving the Company’s corporate integrity, reputation, and operational efficiency.
purpose
To guide the standard of conduct and practice that must be followed in the implementation of the KYC
To protect the Company against fraud, reputation and other financial market risks
To minimize the risks faced by the Company from proceeds of crime
To prevent money laundering and to establish ERM systems to monitor the Company’s exposure to financial crime
compliance
Formulate and implement internal controls and other procedures that will deter criminals from using its facilities for money laundering and terrorist financing and ensure that its obligations under local and international subsisting laws and regulations are met
Embark on ERM and maintain an ERM register
Designate an Officer with the relevant competence and independence to implement the Company’s AML/CFT compliance policy
Comply with the Money Laundering (Prohibition) Act, the Money Laundering (Prohibition) (Amendment) Act (together, the Money Laundering Act), and the Economic and Financial Crimes Commission Act
Identify and report any suspicious transactions derived from the criminal activities defined in AML/CFT Regulations
Ensure the implementation of the requirements of the AML/CFT Act is not inhibited through the Company’s Confidentiality Agreement or Policy
Effectively communicate and raise staff awareness on AML/CFT issues
know your client
KYC is the due diligence that the Company must perform to identify their clients and ascertain relevant information before carrying out any financial businesses with them.
The Company in upholding its KYC policies shall undertake the following:
Issue a KYC compliance form to clientsObtain the necessary documents and information from every client
Report suspicious activities and transactions to the regulatory authorities
Update client information as and when available
Identify the client and verify the client’s identity using reliable, independent source documents (e.g. passport data page, national ID card, voters card, and utility bills stating their current postal address. e.t.c), data or information
Verify the legal status of business names, incorporated trustees, and companies with relevant authorities
Refuse to transact business with “shell companies” as described under the International Conventions
Conduct due diligence for higher-risk clients, business relationships, or transactions including PEP, cross-border transactions, and business relationships
record keeping and reporting
The Company shall keep the record of a customer’s identification for a period of at least five years after the closure of the account or the severance of relations with the customer; and upon request by a regulatory or law enforcement agency, the Company shall make available records related to AML/CFT compliance or its clients as soon as possible from the date of the request.
If the company notices any criminal transaction, it shall:
Draw up a report on the identity of the principal and the beneficiary or beneficiaries;
Take appropriate action to prevent the laundering of the proceeds of criminal conduct;
Send a copy of the report and action taken to the Financial Intelligence Unit (FIU), or its equivalent in local jurisdictions.
Politically Exposed Persons Business relationships with family members or close associates of PEPs involve reputation risks similar to those of PEPs themselves. The Company shall evaluate the risks to its business operations when dealing with PEPs. Sanctions A breach of the AML/CFT is a serious offense and could lead to investigations, imposition of fines, and criminal sanctions (including imprisonment)
