Everything-FXC ANTI MONEY LAUNDERING (“AML”) & COUNTER TERRORIST FINANCING (“CTF”) POLICY
Money laundering is defined as the process of creating the appearance that large amounts of money obtained from serious crimes, such as drug trafficking or terrorist activity, originated from a legitimate source. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm’s knowledge.
The United States, and the United Kingdom, along with a number of other countries, have passed legislation designed to prevent money laundering and to combat terrorism. This legislation, combined with industry regulations, and guidance, establish the basis for AML/CTF obligations in the U.S., U.K. and various other countries and outline the offences and penalties for failing to comply.
While Everything-FXC is currently domiciled in St. Vincent, and does not fall with the jurisdiction of a country requiring compliance with the AML/CTF obligations of the U.S. or U.K., the senior management has implemented systems and procedures that meet the UK AML legislation. This decision reflects the senior management’s desire to prevent money laundering and prevent the use of Everything-FXC by criminals intending to launder proceeds from criminal activities.
AML LEGAL AND REGULATORY FRAMEWORK:
The UK AML regime is set out in the following legislation and regulations:
- The Proceeds of Crime Act 2002 (POCA), as amended by the:
- Serious Organised Crime and Police Act 2005 (SOCPA); and the
- Proceeds of Crime Act (Amendment) Regulations 2007;
- The Terrorism Act 2000, as amended by the:
- The Anti Terrorism, Crime & Security Act 2001; and the
- Terrorism Act (Amendment) Regulations 2007;
- The Terrorism Act 2006;
- The Money Laundering Regulations 2007; and
- The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on the prevention of money laundering/combating terrorist financing
ANTI-MONEY LAUNDERING (AML) POLICY:
The Everything-FXC AML Policy is designed to prevent money laundering by meeting the UK AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
- The appointment of a Money Laundering Reporting Officer (MLRO) who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
- Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
- Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
- Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- The maintenance of appropriate records for the minimum prescribed periods;
- Training and awareness for all relevant employees
Everything-FXC is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Everything-FXC will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.
Anti-Bribery & Anti-Corruption Policy:
Everything-FXC has a zero tolerance policy towards bribery and corruption. Everything-FXC recognizes that bribery and corruption have an adverse effect on communities wherever they occur. If endemic, they can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organized crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies. Everything-FXC is committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings.