AML / KYC Policy is socially conscious of its responsibilities and committed to the welfare of its customers. We strictly adhere to the Anti-Money Laundering Program, which enable us to recognize and report dubious transactions.Money Laundering is an illegal process used to disguise the source of the money and every effort is taken to prevent such criminal activity. The staff is specifically trained to ensure total compliance with the regulations and extensive records are maintained to prevent any kind of fraud.

The company has a strong KYC policy and it records each and every transactions


Basic Policies and Principles to Combat Money Laundering and Terrorist Financing

In 1990, the FATF put forward 40 recommendations (now known as the “40 Recommendations”) aimed at improving national legal systems, enhancing the role of financial systems, and strengthening international co-operation against money laundering. These 40 Recommendations are now recognised as the international standard to prevent money laundering. In October 2001 and October 2004, the FATF supplemented the 40 Recommendations with 9 Special Recommendations on Terrorist Financing.

To ensure compliance, remittance and money changing businesses should have in place the following policies, procedures and controls:

(a) Businesses should issue a clear statement of policies in relation to anti-money laundering and counter terrorist financing, adopting current regulatory requirements. This statement should be communicated in writing to all management and relevant staff whether in branches, departments, or subsidiaries, and should be reviewed on a regular basis.

(b) Instruction manuals should set out the businesses’ procedures for:

§  Occasional transactions;

§  Account opening;

§  Client identification;

§  Record keeping; and

§  Reporting of suspicious transactions.

(c) Businesses should actively seek to promote close co-operation with law enforcement authorities, and should identify a single reference point within their organization (usually a compliance officer) to which staff are instructed to report suspected money laundering or terrorist financing transactions promptly. This reference point should have a means of liaison with the, which is responsible for the analysis and dissemination of such reports to the appropriate law enforcement agency. The role and responsibilities of this reference point in the reporting procedures should be clearly defined.

(d) Measures should be undertaken to ensure that staff are educated and trained on matters contained in this Guideline, both as part of their induction procedures and at regular future intervals. The aim is to generate and maintain a level of awareness and vigilance among staff, so as to enable a report to be made if suspicions are aroused. (e) Businesses should instruct their internal audit/inspection departments to verify, on a regular basis, compliance with policies, procedures, and controls against money laundering and terrorist financing activities.

Customer Identification Requirements for Transactions of $8,000 or more

The customer due diligence process should comprise the following:

a.        For all face-to-face customers, the customer’s identity by reference to, and physical inspection of, their original Identity Card or passport for all transactions of $8,000 or more.

b.        Identify beneficial ownership and control, i.e. determine on whose behalf an account is maintained or on whose behalf a transaction is being conducted (i.e. the beneficial owner), corroborating the information provided wherever possible; and

c.        Conduct on-going due diligence and scrutiny i.e. perform on-going scrutiny of the transactions and account throughout the course of the business relationship to ensure that the transactions being conducted are consistent with the businesses’ knowledge of the customer, his activity and risk profile, including, where necessary, identifying the source of funds.

Where any customer undertakes a transaction on behalf of a third party, in addition to recording and verifying the identity of the customer, the business should also record and retain the identity and full particulars of the instructing third party.

Unwillingness of the customer, for no good reason, to provide the information requested and to cooperate with the businesses’ customer due diligence process, may in itself be a factor that should trigger suspicion. If a customer refuses to provide his identity card or passport for verification, the transaction should be refused.

It is appreciated that no form of identification can be fully guaranteed as genuine or representing correct identity. Businesses are expected to demonstrate a reasonable level of diligence in this respect. The Immigration Department operates a Hotline to which enquiries can be made concerning the validity of an identity card. If there is doubt whether an identification document is genuine, assistance should be sought through this Hotline immediately.

Corporate Customers

The following documents or information should be obtained in respect of corporate customers which are registered (comparable documents, preferably certified by qualified persons such as lawyers or accountants in the country of registration,):

a.        Certificate of Incorporation and Business Registration Certificate;

b.        Memorandum and articles of association;

c.        Resolution of the board of directors to open an account and confer authority on those who will operate it; and

d.        Satisfactory evidence of the identity of the principal shareholders, at least two directors (including the managing director) and all authorized signatories in line with the requirements for individual applicants, as well as evidence of the nature of the business.


This is in addition to recording and verifying the identity of any individual purportedly representing the company, Evidence of the individual’s authority to do so should also be sought and retained.