Anti Money-Laundering Policy Statement and Program Procedures
The Anti Money Laundering Program Procedures is developed, within the context of the Law, for the prevention and suppression of money laundering activities and terrorist financing. The procedure is developed to cover all procedures affected by the Law and to demonstrate the required due diligence on behalf of financial institutions such as banks, insurance companies and money transfer companies.
In addition to the Manual, the corresponding policies and forms are developed to facilitate and documented implementation. Customer identification, acceptance and evaluation, Monitoring and control of transactions, Internal reporting, review and renewal of customer identification, working with third parties, Management of employees are examples of the areas addressed.
Overview of the AML Policy
City Express Money Transfer Pvt. Ltd is the money transfer company licensed by the central bank of Nepal and as an entity as one of the largest money transfer company has an important role to play in furthering the local and international efforts against money laundering and terrorist financing. The most effective way to fulfill this commitment and to protect both the company and its staff is to know your customer, be alert to suspicious activity and train all staff to be proficient at identifying suspicious activity on a regular basis.
Overview of the AML procedures Manual
This manual contains the procedures that must be followed and controls that must be implemented by all AML staff and agents to ensure compliance with both local and relevant international AML legislation.
The company will review and update these procedures at least annually to take into consideration changes to the products, business conditions and regulatory environment. The annual review will also be used to evaluate how accurately the procedures reflect the product and how effectively they are in controlling the AML threat.
All changes to this procedure manual must be approved by the management with significant changes also being approved by the management.
AML Compliance Officer Designation and Duties
As required under the AML Policy Act, the Company designates (name of AMLCO) as the Anti-Money Laundering Program Compliance Officer, with full responsibility for the Company's anti-money laundering (AML) program. The AML Compliance Officer will also ensure that proper AML records are kept. When warranted, the AML Compliance Officer will ensure Suspicious Activity Reports are filed with the Company's designated self-regulatory agency.
Checking the office of Foreign Assets Control (OFAC) Lists
Before engaging in any money service activity (including but not limited to check cashing, money orders and wire transfers) which potentially may involve money laundering, and on an ongoing basis, we will check to ensure that a customer does not appear on the Treasury's OFAC “Specifically Designated Nationals and Blocked Persons” List, SDN List, and is not from, or engaging in transactions with people or entities from, embargoed countries and regions listed on the OFAC website. Because the OFAC Website is updated frequently, we will consult the list on a regular basis and subscribe to receive updates when they occur. We may, if necessary, access these lists through various software programs to ensure speed and accuracy. We will also review existing accounts against these lists when they are updated and we will document our review.
Customer Identification and Verification
We have established, documented, and maintained a written Customer Identification Program (or CIP). We will collect certain minimum customer identification information from each customer who engages in any money service activity with the Company; utilize risk-based measures to verify the identity of each customer who engages in any money service activity; record customer identification information and the verification methods and results; provide notice to customers that we will seek identification information.
Monitoring Accounts for Suspicious Activity
We will manually monitor a sufficient amount of money service activity to permit identification of patterns of unusual size, volume, pattern or type of transactions. The AML Compliance Officer will be responsible for this monitoring, will document when and how it is carried out, and will report suspicious activities to the appropriate authorities. We will create employee guidelines with examples of suspicious money laundering activity and lists of high-risk clients whose accounts may warrant further scrutiny.
AML Record Keeping
Our AML Compliance Officer and his or her designee will be responsible to ensure that AML records are maintained properly. As part of our AML program, the Company will create and maintain relevant documentation on customer identity and verification and funds transfers and transmittals as well as any records related to customers listed on the OFAC list. We will maintain and their accompanying documentation for at least five years.
Bank Company Relationship
We will work closely with our banking firm to detect money laundering. We will exchange information, records, data and exception reports as necessary to comply with AML laws. Generally we have agreed that the Company will monitor customer activity including proper customer identification information as required.
We developed ongoing employee training under the leadership of the AML Compliance Officer. Our training will occur on at least an annual basis. Based on our firm's size, its customer base, and its resources we have determined the training course to our staff. The training course offered includes, at a minimum: how to identify signs of money laundering that arise during the course of the employees' duties; what to do once the risk is identified; what employees' roles are in the firm's compliance efforts and how to perform them; the Company's record retention policy; and the disciplinary consequences (including civil and criminal penalties) for non-compliance with the Act. The training program includes the maintenance of the records to show the persons trained, the dates of training, and the subject matter of their training.
Monitoring Employee Conducts and Accounts
We will subject employee money service transactions to the same AML procedures as customer accounts, under the supervision of the AML Compliance Officer. We will also review the AML performance of supervisors, as part of their annual performance review. The AML Compliance Officer's accounts will be reviewed by a qualified member of the Company staff.
Confidential Reporting of AML Non-Compliance
Employees will report any violations of the firm's AML compliance program to the AML Compliance Officer, unless the violations implicate the Compliance Officer, in which case the employee shall report to an appropriate member of senior management. Such reports will be confidential, and the employee will suffer no retaliation for making them.
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