We are committed to the prevention of financial crime and have adopted procedures to detect and deter money laundering, terrorist financing or other illegal activities.
It is our policy to deter and, where we can, prevent, the use of our group as a conduit for illegal money laundering activities. We have a comprehensive AML policy in place to guide our staff on the prevention, detection and reporting of any financial crime perpetrated through money Laundering or financing illegal activities. Our staff can only implement this policy if they understand the background to it and how it works in the context of our day-to-day business. The success of our policy depends on the vigilance of everyone.
In order for these policies to be effectively implemented, the financial Institution and its entire staff need to be:
- Informed about the legal and regulatory framework and the serious legal and regulatory penalties for assisting in financial crime - even unwittingly- in every jurisdiction from which we operate.
- Alert to the practical methods by which criminals seek to commit financial crimes.
- Aware of the need to report any suspicions promptly to us.
Our AML policy is premised on the guidelines detailed by the governmental and non-governmental bodies tasked with prevention of financial crimes.
The UK has many laws directed to preventing, detecting and reporting financial crime through money laundering or financing illegal activities.
The UK is part of The Financial Action Task Force ("FATF"), an inter-governmental body whose purpose is the development and promotion of policies, both at national and international levels, to combat money laundering and terrorist financing. FATF has published a series of high-level recommendations which include suggested standards of customer due diligence and record keeping.
At a national level, the Joint Money Laundering Steering Group ("JMLSG") comprised of leading UK Trade Associations in the financial services industry, develops industry good practice through the publication of industry guidance. The most recent guidance is JMLSG
Guidance 2007 which advocates a risk-based approach to preventing financial crime.
We offer our services (e.g., issue of trade finance instruments) to corporate legal entities who have undergone a thorough verification exercise so that we can establish that they are legitimate.
As a number of our agents/ brokers are located in countries which are regarded for money laundering purposes as higher risk - such as Africa, India, Bangladesh - we have adopted a high standard for required documentation before an application will be accepted. We additionally check applicants against international sanctions lists. This verification is completed before we issue any instruments. Before accepting an application for a trade finance instrument, we require documentary proof from the applicant of the legitimate commercial nature of the business. This is because we recognise the risk of being used for improper purposes as described in the examples below.
The JMLSG Guidance emphasises the responsibility of senior management in promoting an effective policy of financial crime prevention. Our Money Laundering Reporting Officer ("MLRO") is a member of senior management with the specific responsibility of overseeing the implementation of our policies to prevent financial crime. The MLRO reports directly to the Board. The Financial Institution and each individual member of staff are required by law to report suspicious transactions, via the firm's MLRO, to Serious Organised Crime Agency ("SOCA"). The individual obligation is satisfied by promptly reporting your suspicions to the MLRO.
We recognise the importance of keeping full and accurate records of the steps taken by us to verify our Applicants. All original documentation is maintained in paper or electronic format for a period of seven (7) years.
We ensure that our staff:
- know what money laundering is and how we might be used to facilitate this.
- understand the need for vigilance in the Applicant take on processes.
- know how to identify and report suspicious transactions.
With this in mind, we conduct periodic refresher training for our staff. The MLRO or other senior management are on hand to answer any questions or deal with concerns on this topic.