Anti-Money Laundering

We use self-assessment tools to assess our compliance with our internal controls, risk management processes and applicable regulations. The results of the self-assessments are regularly reviewed by Senior Management and the Board of Directors.

Maintain a professional Internal Audit function that evaluates the adequacy and effectiveness of internal controls, risk management and governance processes; and their level of compliance with applicable rules and regulations. These internal controls are subject to annual assessments to ensure they remain compliant and applicable to new and prevailing rules.

We recognise the importance of training and development to keep abreast of prudential requirements and best practices. Our staff attend various training programmes related to their duties including governance and risk management practices, and anti-money laundering.

In addition, as part of our induction process, we ensure that employees who are responsible for executing and managing financial transactions undergo mandatory anti-money laundering and compliance training.  It is also a requirement for employees with fiduciary duties to complete an annual anti-money laundering refresher course.

We have employees qualified with certificates and professional memberships from organisations including the Association of Certified Anti-Money Laundering Specialists (ACAMS) and the International Compliance Association.

In accordance with Know Your Customer (KYC) and Source of Wealth (SOW) and Source of Funds (SOF) best practice, and as a condition of our licences we verify the identity and residential address of each of our clients. This requirement is reinforced in our Terms & Conditions. We also undertake checks on client employment and income, ensuring funds deposited are within KYC parameters.

We do not receive third party deposits nor make third party withdrawals.  All deposits are, where possible, returned to source to prevent facilitating the "layering" of fraudulent proceeds.

Alongside this, we use innovative document authentication technology and electronic databases to mitigate the risk of identity fraud, including situations involving stolen identity and the use of counterfeit documents. Where necessary, we will use electronic identification methods with publicly available databases, carrying out biometric checks and/or requesting "selfie certs" or video calls to verify a client’s identity.

We also regularly update our client files with details of their economic profiles and undertake checks for those that may be Sanctioned, Politically Exposed Persons or carrying adverse media.

The Internal Audit function executes an annual risk based plan, testing the effectiveness of internal controls and their compliance with applicable rules and regulations.