Policy statement and principles
In conjunction with the 2002 Financial Intelligence and Anti-Money Laundering Act (FIAMLA 2002), the Prevention of Corruption Act of 2002 (POCA 2002) and the Prevention of Terrorism Act of 2002 (POTA 2002), BIRTH ("BIRTH") has passed anti-money laundering (AML)'s compliance policy ("Policy") is set out in the minutes of the board meeting.
Policy scope
This policy applies to all BIRTH personnel, employees, appointing producers, and products and services provided by BIRTH, and all business units of BIRTH will work together to combat money laundering. Each business unit implements a reasonably based process to prevent, detect, and cause reporting of the transaction risks required under FIAMLA. All efforts generated will be recorded and retained in accordance with FIAMLA. Start suspicious activity reports ("SARs") or other required reports, with appropriate law enforcement or regulatory agencies responsible for the Anti-Money Laundering Compliance Committee. Any contact by law enforcement or regulatory agency related policies should be reported to the Anti-Money Laundering Compliance Committee.
policy
BIRTH's policy is to prohibit and prevent money laundering and money laundering or to fund any activity of terrorist or criminal activity that is conducive to active pursuit. BIRTH is committed to anti-money laundering compliance, in accordance with applicable laws, and requires its staff, employees, and producers to comply with these standards in preventing the use of their products and services for money laundering purposes. For the purposes of this policy, money laundering is usually defined as the act of concealing or disguising the proceeds of a crime, making the proceeds of the law appear to have originated from legal sources or constitute the true origin of the legal assets.
In general, money laundering occurs in three stages. Cash first enters the financial system in the “arrangement” phase, converting cash generated from criminal activities into money instruments, such as money orders or travellers’ checks, or depositing them in financial institutions’ accounts. In the “stratified” phase, funds are transferred or moved to other accounts or other financial institutions to further separate the money from their criminal sources. In the “integration” phase, funds are re-entered into the economy and used to purchase legal assets or funds such as illegal criminal activities or legitimate businesses. Terrorist fundraising activities must not involve the proceeds of a criminal act, but rather an attempt to conceal the origin or intended use of funds, which will later be used for criminal purposes.
Anti-Money Laundering Compliance Committee
The Anti-Money Laundering Compliance Committee, for the full responsibility of the policy, should be the General Counsel, the Chief Compliance Officer, the Deputy Inspector of BIRTH, the Assistant Vice President of BIRTH, the Internal Audit and Corporate Lawyers. The Chief Compliance Officer should also hold the title of Anti-Money Laundering Executive Director and should sign such authority. The responsibilities of the Anti-Money Laundering Compliance Committee with policy include, but are not limited to, design and implementation, as well as the required policies for updating; information dissemination managers, employees and BIRTH appoint producers, training managers, employees, and appoint producers Monitor the situation of BIRTH's business units and appoint producers, maintain necessary and appropriate records, submit SARs when needed; and independently test the operation of the policy. Each BIRTH business unit should assign a contact person to interact directly with the Anti-Money Laundering Compliance Committee to assist with investigations, monitoring and otherwise requesting the committee.
Customer identification program
BIRTH has adopted the Customer Identification Program (CIP). BIRTH will provide notice that they will receive a certain minimum customer identity information, records, etc. from each customer seeking identification information and verifying the customer identity information results with OFAC.
Customer notice
BIRTH will provide notice to the customer asking them to provide information to verify their identity as a rule of applicable law.
Verify information
Depending on the extent to which the risk is reasonable and feasible, BIRTH will ensure that it has reasonable grounds to believe in the true identity of its customers. In verifying the identity of the client, the appointing executor should review the identity of the photo. BIRTH must not attempt to determine if the documents provided by the customer for identification have been validated. For verification purposes, BIRTH should rely on government-issued ID cards to establish the identity of the customer. However, BIRTH will analyze the information provided to determine if there is any logical inconsistency in the information obtained. The documents that BIRTH will check include all information that is determined by the customer, the method used, and the results of the verification, including but not limited to signing the identity certificate by appointing the performer to match the photo.
Those who refuse to provide information
If the customer refuses to provide the information request described above, or if the intentionally provides misleading information, the appointed agent should notify the new business team. BIRTH's new business team will reject the application and notify the Anti-Money Laundering Compliance Committee.
Checked list of Foreign Asset Control Offices (OFAC)
For all (1) new things received and ongoing, (2) payment, (3) newly appointed managers, (4) new employees, BIRTH will check to make sure that one person or entity does not appear in the Ministry of Finance The Office of Foreign Assets Management, which specifically lists the list of nationals and blockades (SDN lists), or engages in transactions with people or entities, is not listed on the website of the Foreign Assets Management Office of the embargoed countries and regions. BIRTH should work with World – Check to ensure the speed and accuracy of the inspection. BIRTH will also regularly review existing policy holders, producers and employees on these lists. The frequency of comments will be recorded and saved. The business unit will compare the SDN list or other OFAC lists, and if it finds a matching list will be reviewed. If the comparison cannot be confirmed illegal, the Anti-Money Laundering Committee will be notified.
Monitoring and reporting
Transaction-based monitoring will appear in the appropriate business unit of BIRTH. The monitoring of specific transactions, including but not limited to BIRTH, has a reason to suspect a gathering of suspicious activities of $5,000 or more, and all reports of those transactions will be recorded and retained in accordance with FIAMLA requirements.
Suspicious activity
There are signs of suspicious activity with money laundering. These are often referred to as "red flags." If a red flag is detected, additional due diligence will be conducted prior to the transaction. If a reasonable explanation is not established, suspicious activity should be reported to the Anti-Money Laundering Compliance Committee. Example of red flag:
The client’s unusual attention and government reports require the company to comply with the company’s anti-money laundering policy, particularly respecting his or her identity, business and asset type, or unwilling or refusing to disclose any information about business activities, or provide Unusual or suspicious identification or business documents.
Clients wish to engage in transactions, lack a business-aware or obvious investment strategy, or be inconsistent with the client's business strategy.
The information provided by the client to determine the legal source of funds is false, misleading, or to a considerable extent incorrect.
Upon request, the customer refuses to determine or fails to indicate any legal source of his or her funds and other assets.
The client (or someone who is publicly associated with the client) has a suspicious background or is the subject of a possible criminal, civil, or regulatory violation of the news report.
Customer exhibits lack the relevant risks, commissions, or other transaction cost concerns.
It appears to be an undisclosed primary proxy client, but refuses or is unwilling, has no legitimate business reasons, provides information or otherwise evades the person or entity concerned.
The client has difficulty describing his or her commercial nature or lacking general knowledge of his or her industry.
Clients attempt to make frequent currency or large deposits, insisting on company policies that only involve cash equivalents, or require exemptions from deposits related to cash and cash equivalents.
Clients engaged in transactions involving cash or cash equivalents or other monetary policy instruments are structured to avoid the $10,000 government reporting requirement, especially if the cash or currency instrument is slightly below the reported or recorded threshold amount.
For no apparent reason, a customer has multiple names or multiple names for an account to be placed, with a large number of cross-accounts or third-party transfers.
The client, or account, is identified as a non-cooperative country or region by a national financial action task force.
The client's account has a wide range of unexplained or sudden-outline activities, especially those with little or no activity before.
The customer's account has a large number of third-party wire transfers that are not related to the legitimate business purpose of the customer.
The customer's account, wire transfer, has no obvious commercial purpose or is determined by a country as a money laundering risk or bank secrecy paradise.
Without any obvious commercial purpose, the customer's account shows a large or frequent wire transfer and immediately withdraws the check or debit card.
Without any obvious commercial purpose, the client immediately requested that the deposit funds be transferred to a third party or to another company.
The client requests the status of the liquidation and the transferred income account, shortly thereafter, followed by the fund deposit for the purpose of purchasing the long-term investment.
Excessive diary entries between accounts that are unrelated to the client without any obvious commercial purpose.
Transactions are processed in this way to avoid customer requests for the company's normal documentation requirements.
The client has no obvious reason, or in conjunction with other red flags, to engage in certain types of securities, such as penny stocks and bearer bonds, which are legal, have been linked to fraudulent activities and money laundering transactions (such transactions may require further Due diligence to ensure the legitimacy of the client's activities).
The customer's account activity shows a very low level of high-level securities trading for unknown reasons.
Try to borrow money to buy the maximum cash value of a single land price policy shortly after purchase.
If you specify a manufacturer:
· Dramatic or unexpected sales increase
· consistently high activity exceeds company average single premium contract
· Sudden changes in lifestyle
· The requested client file is transferred to the proxy
survey
After the OFAC SDN list or suspicious activity may match the notice of the Anti-Money Laundering Compliance Committee, an investigation will be initiated to determine whether a report should be made by the appropriate law enforcement or regulatory agency investigation will include, but is not necessarily limited to, all available information, Such as payment records, date of birth, address, review, if the results of the investigation are warranted, it is recommended that the AML Compliance Committee's documents be blocked with the appropriate law enforcement or regulatory agencies and/or SAR. The Anti-Money Laundering Compliance Committee, responsible for any notifications or filing results with law enforcement agencies or regulatory agencies will not be disclosed or discussed other than those who have legitimate needs to know. In any case, any officer, employee or appointed agent discloses or discusses any anti-money laundering concerns, investigations, notices or persons submitted by the SAR Government or persons on such topics, or any other person, including members of the relevant personnel , the employee or the family of the designated agent.
Record saving
The Anti-Money Laundering Compliance Committee will be responsible for ensuring that anti-money laundering records are maintained in the correct SARS and blocked property reporting requirements. BIRTH will maintain a record of anti-money laundering for at least five years.
Training
BIRTH should provide its staff, employees, and appoint producers with general anti-money laundering training to ensure awareness of the requirements at FIAMLA. Training will at least include: how to identify signs of red flags and money laundering; what role managers, employees, and appointed managers follow and how to perform these duties and responsibilities; how to do a red check mark or suspicious activity; BIRTH record retention Policy; Act "and this policy does not comply with the consequences of discipline. In addition, each affected area will follow the requests of developers and employees in each field, reasonably expected to handle the money, or processing may make them accessible to the above designation The information program provides intensive training. The training course will be conducted on an annual basis. The BIRTH Anti-Money Laundering Compliance Committee will determine ongoing training requirements and ensure that written procedures are updated to reflect any changes required for this training. BIRTH will retain A document that has been trained.
Test strategy
Test policies will be conducted annually by externally independent third parties. Any results will be reported to the Anti-Money Laundering Compliance Committee, the SFG Audit Committee and senior management to take appropriate action.
Government affairs
The Anti-Money Laundering Compliance Committee is responsible for the management, revision, interpretation and application of this policy. The policy will be reviewed and revised annually as needed.
