Purpose
This policy describes the framework used to reduce the risk of money laundering, terrorist financing and other prohibited financial activity.
Customer Due Diligence
Customer due diligence should be completed using approved identity, address, ownership and verification procedures.
Identity Verification
Identity information may be checked against appropriate verification sources and, where required, sanctions, politically exposed person or adverse-media screening.
Source of Funds
Where required by law or internal controls, information may be requested regarding source of funds, source of wealth, business activity or beneficial ownership.
Ongoing Monitoring
Customer relationships and transactions may be monitored using risk-based procedures designed to identify unusual, inconsistent or potentially prohibited activity.
Suspicious Activity
Concerns may be escalated internally and reported to relevant authorities in accordance with applicable law. Confidential reporting procedures should not be disclosed on a public website.
Record Keeping
Compliance records should be retained for the period required by applicable law and the approved record-retention policy.
Cooperation & Updates
The final policy must reflect the client’s actual legal entity, jurisdictions served, responsible compliance function and applicable laws.