Anti Money Laundering Policy

Objective

Worldwide regulations require that we do not engage with organisations which could be
subject to Money Laundering or Terrorist financing. Any such association can have
significant reputational and/or financial implications for the Firm. It is therefore important
we carry out detailed Anti Money Laundering (AML) checks on all our business
relationships.

Policy

● We do not enter into any business relationship that can lead to us directly or
indirectly associated with money laundering activities.
● It is important that we identify Ultimate Beneficial Owners (UBOs) for each
business relationship.
● Anti Money Laundering Officer will be responsible for implementing policies and
procedures, ensuring the guidance is updated, distributed to all staff and partners
and keeping a track of all exceptions.
● All AML exceptions need to be highlighted to the AML Officer and no relationship
can continue if there is any perceived or actual AML non-compliance.
● Local country AML procedures, laws and guidance have to be followed as well.

Definition

Money laundering is the masking the creation of illegal funds or assets, proceeds of
crime, generated from criminal or illegal means in a way such that the source appears
to be legitimate.

There are various techniques that are used worldwide, with some very innovative and
thorough professionals to launder money or assets. Therefore, there always remains a
risk that we might be associated with money laundering activities if our checks and
balances are not applied appropriately.

Guidance

Timing of AML checks

AML procedures should be performed before accepting any client or engagement.

These procedures need to be applied on continuing engagements as well.
What to look out for

● Perform procedures to identify the source of the business relationship’s source of

funds.
● Run worldwide checks (e.g., World Check in Moore Intranet), media searches to
identify if the client has any negative publicity.
● Identify the UBO. For the purpose of clarity, a UBO is defined as an individual
that holds 25% interest or more in the client.
● Verify the identity of the UBO where identified. This could involve using an
external source or vendor, obtaining identification information such as passports,
IDs, utility bills and residential addresses.
● Understand how the control is structured. An extremely complex group structure
with multiple entities layered in tax havens should be understood. Analyse
whether the service being requested is consistent with our understanding of the
entity.
● Judgement needs to be applied as to what could be considered as sufficient and
appropriate. For example, an entity is publicly listed, a mere check on the stock
exchange could be considered sufficient for AML procedures.
● Politically Exposed Persons (PEP’s) - As per the Financial Action Task Force
(FATF), a politically exposed person (PEP) is an individual who is or has been
entrusted with a prominent function. Many PEPs hold positions that can be
abused for the purpose of laundering illicit funds or other predicate offences such
as corruption or bribery. Because of the risks associated with PEPs, the FATF
Recommendations require the application of additional AML measures to
business relationships with PEPs.
In such relationships, the Firm can be exposed to reputational risk if we were to
be associated in a business relationship with someone involved in illegal use of
public money, bribery or corruption. As a minimum, the following steps should be
taken:

○ Perform additional verification procedures by verifying identity.

○ Accept only after consulting and obtaining the required approvals.
○ Establish the source of wealth.
○ Perform enhanced monitoring of the relationship.

Documentation

All documentation reviewed and procedures performed have to be stored and

documented that will be useful in a possible inquiry, investigation by regulatory
authorities. Such documentation should be kept for a minimum of ten years.