ANTI-MONEY LAUNDERING (AML POLICY)
Money laundering is the act of converting money or other material values gained from illegal activities (terrorism, drug dealing, illegal arms trade, corruption, human traffic etc.) into money or investments that appear to be legitimate. Such activities are performed so that the illegal source of money and other material values are not able to be traced.
POLICY STATEMENT AND PRINCIPLES
FintechFX has adopted a programme that complies with the AML/CTF Act. As part of this process, you will need to provide evidence of identification to facilitate the above mentioned need for compliance.
SCOPE OF POLICY
- This policy applies to all FintechFX officers, employees, appointed producers, products and services offered by FintechFX.
- All business units and locations within FintechFX will cooperate to create a cohesive effort in the fight against money laundering. Each business unit and location has implemented risk-based procedures reasonably expected to prevent, detect and cause the reporting of transactions required under the International Anti Money Laundering Law.
- All effort exerted will be documented and retained in accordance with the Anti-Money Laundering Law. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (“SARs”) or other required reporting to the appropriate law enforcement or regulatory agencies. Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee.
It is the policy of FintechFX to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.
FintechFX is committed to AML compliance in accordance with applicable law and requires its officers, employees and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.
CUSTOMER IDENTIFICATION PROGRAM
FintechFX will provide notice to clients requesting personal information for verification purposes, as required by the applicable laws and policies. Clients are expected to provide clear and concise identification along with full disclosure upon further inquiries by The Company.
Photo identification will be required in the process of verifying a client’s identity. FintechFX will not attempt to determine whether the document that the client has provided for identification has been validly issued. FintechFX will rely on a government-issued identification to establish a client’s identity. FintechFX however will analyse the information provided to determine if there are any logical inconsistencies in the information obtained.
FintechFX will document its verification, including all identifying information provided by the client, the methods used and results of the verification, including but not limited to sign-off by the appointed producer of matching photo identification. FintechFX reserves the right to request for further particulars from the client subsequent to provision of the primary government-issued identification for further verification purposes.
FintechFX reserves the right to suspend or void a client’s account that had been approved upon evidence that the particulars provided are misleading and fraudulent.
CLIENTS WHO REFUSE TO PROVIDE INFORMATION
If a client either refuses to provide the information described above when requested or appears to have intentionally provide misleading information, the appointed agent shall proceed to notifying their Business Team. FintechFX will consequently decline the application and notify the AML Compliance Committee.
MONITORING AND REPORTING SUSPICIOUS ACTIVITY
FintechFX collects and verifies identification data of clients by logging and tracking all itemized statements of all transactions carried out and executed.
If FintechFX detects any suspicious transactions or any transactions executed under nonstandard conditions, The Company has the obligation to undertake appropriate measures associated with its Anti Money Laundering compliance based on AML FATF recommendations.
FintechFX neither accepts cash deposits nor disburses cash under any circumstances. FintechFX reserves the right to refuse processing any transactions at any stage in cases where the requested action is believed to be connected in any way/form of money laundering or criminal activities. In accordance with standard international law, FintechFX is not obligated to inform the client when suspicious activities are detected and reported to the corresponding governing bodies.
The following list of suspicious activities are not meant to be exhaustive and FintechFX reserves the rights to categorize or deem any transaction or activity as suspicious:
- The client exhibits unusual concern regarding the firm’s compliance with government reporting requirements and the firm’s AML policies, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual identification or business documents.
- The client wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the client’s stated business strategy.
- The information provided by the client that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
- Upon request, the client refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
- The client (or a person publicly associated with the client) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
- The client exhibits a lack of concern regarding risks, commissions, or other transaction costs.
- The client appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.
- The client has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.
- The client attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents, or asks for exemptions from the firm’s policies relating to the deposit of cash and cash equivalents.
- The client engages in transactions involving cash or cash equivalents or other monetary instruments that appear to be structured to avoid the $10,000 government reporting requirements, especially if the cash or monetary instruments are in an amount just below reporting or recording thresholds.
- For no apparent reason, the client has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
- The client is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force.
- The client’s account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity.
- The client’s account shows numerous currency or cashier’s check transactions aggregating to significant sums.
- The client’s account has a large number of wire transfers to unrelated third parties inconsistent with the client’s legitimate business purpose.
- The client’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a bank secrecy haven.
- The client’s account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose.
- The client makes a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.
- The client makes a funds deposit for the purpose of purchasing a long-term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account.
- The client engages in excessive journal entries between unrelated accounts without any apparent business purpose.
- The client requests that a transaction be processed in such a manner to avoid the firm’s normal documentation requirements.
- The client, for no apparent reason or in conjunction with other red flags, engages in transactions involving certain types of securities, such as penny stocks, and bearer bonds, which although legitimate, have been used relating to fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the client’s activity.)
- The client’s account shows an unexplained high level of account activity with very low levels of securities transactions.
If the appointed producer:
- Exhibits a dramatic or unexpected increase in sales (particularly of single premium contracts).
- Has consistently high activity in single premium contracts in excess of company averages.
- Exhibits a sudden change in lifestyle.
- Requests client documentation be delivered to the agent.
OUR COMPLIANCE REGIME
As required under laws regulating financial institutions, FintechFX has in place a compliance regime including appointment of a compliance officer, preparation of policies and procedures, periodic review of their effectiveness and ongoing compliance training of our staff.
FintechFX is committed to regularly update its electronic system for inspection of suspicious transactions and for verification of client identification records, in accordance with any new regulations as they are promulgated, as well as providing training for its employees on enhancements to anti-money laundering procedures that may be required by new regulations.