Anti-Money Laundering and Terrorist Financing PolicyLast published: 03 August 2023
This policy describes the risk-based approach to ensure full compliance with all applicable laws and regulations regarding anti-money laundering procedures, in order to prevent and detect money laundering, terrorist financing and other illegal activities, and to adhere to relevant legislation such as the Financial Intelligence Centre Act. 1. Scope1.1. This policy covers all individuals working at all levels and grades, including managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual staff and volunteers (collectively referred to as staff or employees).1.2. Breach of this policy will be dealt with under our Disciplinary Procedure which could result in dismissal after due process is followed.2. Review Of This PolicyThe policy shall be reviewed annually to ensure that it meets legal requirements and reflects best practice. The company can change the policy from time to time.3. Policy3.1. The governing body remains responsible for ensuring a culture of compliance and remains ultimately responsible for ensuring that an effective internal anti-money laundering and terrorist financing control structure is maintained and effectively implemented.3.2. It is the policy to assess the risk of anti-money laundering and terrorist financing in the Cometa Group. 3.3. The commitment to this objective is included in this document for adequate prevention and control. It includes procedures for the detection and reporting of activities possibly linked to money laundering or the financing of terrorist activities. 3.4. This risk management aims to:
  • Identify;
  • Assess;
  • Monitor;
  • Mitigate;
  • Manage
any Money Laundering and terrorist financing risks that the Cometa Group may encounter.3.5. The following concepts and approach for the effective implementation of requirements has been introduced:
  • A risk based, as opposed to “rules based” compliance management program, based on the unique identified risks of the entity.
  • A full range of risk-based Customer Due Diligence (“CDD”) and Enhanced Due Diligence (“EDD”) requirements which are focused on understanding customers and getting to adequately “Know Your Client” (“KYC”) as opposed to simply identifying and verifying identities.
  • A risk-based KYC approach to ensure the efficient utilization of resources and easier compliance for low-risk clients.
  • Due diligence and KYC procedures to identify ultimate beneficial ownership, which require the knowledge and understanding of the natural persons who ultimately own or exercise control over legal entities or structures.
  • Risk management relating to relationships with Prominent Influential Persons (“PIP”) and Foreign Prominent Public Officials (“FPPO”).
  • The provision for the freezing of assets, in terms of targeted financial sanctions against persons identified by the United Nations Security Council in terms of various sanctions regimes.
  • Procedures for the reporting of transactions where required and for cooperation with the Financial Intelligence Centre in respect of the provision of required information.
  • Procedures to ensure robust record retention.
3.6. To ensure effective control and management, regular and timely information relevant to the management of the money laundering and terrorist financing risks shall be provided to the governing authority and a perpetual record of risk management policies and Cometa Group’s risk profile in relation to money laundering and terrorist financing, including documentation of the institution’s application of those policies, shall be maintained.3.7. Compliance with the anti-money laundering and terrorist financing compliance is integral to the overall commitment to combat money laundering, terrorist financing and other crimes. 3.8. The appropriate application is for staff to be familiar with the contents, related procedures, and norms that regulate these activities to prevent the use of our products and services for money laundering purposes, terrorist financing or other financial crime.  3.9. Staff must at all times, comply with the Cometa Group policies and procedures, which are subject to review by local regulators and/or independent external auditors if such reviews are required by local law or regulations.  3.10. Failure to adhere to the requirements may result in disciplinary or other action as prescribed in the terms of employment and the possibility of criminal sanction.3.11. A copy of this document shall be made available to every staff member and all applicable staff shall receive appropriate training in alignment with Cometa Group’s unit risk assessment.3.12. On request from the Financial Intelligence Centre (“FIC”) or a regulatory body, a copy of the document describing the Risk Management and Compliance Program shall be made available to the Financial Intelligence Centre and any other regulator.
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