Anti Money Laundering (AML) Policy for VSL Vyking Software LTD
Policy Owners:
Compliance Department and AML Officer.
The Compliance Department oversees the implementation of this policy, while the AML Officer is responsible for collecting all data related to money laundering, collaborating with the FIU, and making STRs and/or Unusual Transactions when necessary.
1. Introduction
1.1 Money Laundering
Money Laundering (ML) is the process of creating the appearance that funds obtained from criminal activity, such as drug trafficking or terrorism, originate from a legitimate source. Criminals launder money by disguising the source, changing the form of the funds, or moving them to places where they are less likely to attract attention.
1.2 Anti-Money Laundering
Anti-money laundering (AML) refers to the legal controls that financial institutions and other regulated entities must follow to prevent, detect, and report ML activities.
An effective AML program requires:
Criminalization of money laundering.
Giving relevant regulators and police the powers and tools to investigate it.
Requiring financial institutions to identify customers, establish risk-based controls, keep records, and report suspicious activities.
Information-sharing between jurisdictions as appropriate.
2. Regulation
Employees must report any information obtained during the course of their business when:
They know.
They suspect.
They have reasonable grounds for knowing or suspecting money laundering or terrorist financing.
3. Crime & Disorder and AML policy
The AML policy is based on these principles:
We develop systems and controls to comply with legal and regulatory requirements.
We assess AML risks annually and adopt a risk-based approach.
Senior management is fully committed and responsible.
We regularly assess the adequacy of our systems and controls.
We maintain records of transactions for law enforcement investigations.
We provide ongoing AML training for employees.
4. Risk Management
We follow a risk-based approach to assess and manage money laundering and terrorist financing risks by:
Identifying relevant risks.
Designing policies to mitigate these risks.
Monitoring and improving the controls.
Keeping detailed records of our processes.
5. Suspicious Activity
Suspicious activity refers to unusual transactions or deposits that do not match normal patterns. Examples of required documents include:
Passport or ID card.
Utility bill.
Bank statement.
5.1 Suspicious Activity Reports (SARs)
We must comply with the jurisdiction’s regulations, including the reporting of unusual transactions to the Financial Intelligence Unit (FIU).
6. Employees
6.1 Senior Management
Senior management is fully responsible for the implementation of this policy and are aware of their liability under the AML Regulations.
6.2 Risk Management Officer
A designated Risk Management Officer handles SARs and reports AML activities to senior management, receives disclosures from employees, and makes external reports if necessary.
7. High Risk Jurisdictions
High-risk countries identified by the Financial Action Task Force (FATF) are not accepted. Examples include Afghanistan, Iran, Iraq, North Korea, Syria, and Yemen.
8. Record Keeping
We ensure that an audit trail is maintained to assist in financial investigations. Records are kept for at least 6 years.
9. Vetting Procedures for New Employees
Proper identification checks and independent references are obtained before hiring new employees.
10. Protecting Equipment from Criminal Misuse
We identify and protect key assets from misuse by implementing controls within the company’s business processes.
11. Compliance and Risk Committee
This committee meets quarterly or as required to review compliance and risk-related matters.
12. Ensuring Trustworthy Business Relationships
We only work with suppliers that demonstrate financial strength, legal and regulatory compliance, and the ability to deliver quality services.
13. Internal Record Keeping
Records of customer transactions, customer details, and investigations into money laundering are kept for at least 6 years.
14. Risk-Based Approach
14.1 Risk-Assessment Procedures
We assess money laundering risks posed by customers, products, and services through customer profiling, product risk evaluation, and geographical risk assessment.
14.2 Customer Risk
Customer risk is based on economic activity or source of wealth. High-risk customers are monitored more actively, and enhanced due diligence is conducted where necessary.
14.3 Product/Service Risk
We assess risks associated with products and services. Our business is inherently risky, but we mitigate these risks by not dealing with anonymous transactions, only accepting deposits from regulated financial institutions, and conducting thorough Know Your Client (KYC) procedures.
14.4 Interface Risk
Internet-based services pose higher risks due to the speed and anonymity of online transactions. We do not accept anonymous transactions and carry out KYC procedures to mitigate this risk.
14.5 Geographical Risk
We assess the geographical location of customers and their economic activity to determine the risk. Transactions to or from sanctioned countries, or countries with high levels of corruption, are considered higher risk.