ANTI-MONEY LAUNDERING POLICY
The phrase “money laundering” covers all procedures to conceal the origins of criminal proceeds so that they appear to originate from a legitimate source. Fair Price LLC (“Company”) aims to detect, manage and mitigate the risks associated with money laundering and the financing of terrorism. The Company has introduced strict policy aimed on the detection, risk prevention or mitigation in respect of any suspicious activities performed by customers. The Company is required to constantly monitor its level of exposure to the risk of money laundering and the financing of terrorism.
Customer due diligence
Effective Customer Due Diligence (”CDD”) measures are essential to the management of money laundering and terrorist financing risk. CDD means the identification and verification of the true identity of the customer on the basis of records, data or details, both at the time of initiation of the customer’s business relationship and on an ongoing basis. The identification and verification procedures of the customer include, first, the collection of information and, second, the attempt to verify that information.
During the FairPrice registration process an individual customers provide the following identification information to the Company:
- Customer’s full name;
- Country of residence/location of customer;
- Mobile telephone number and e-mail.
During the FairPrice registration process a corporate customers provide the following identification information to the Company:
- Full name;
- Registered address;
- Mobile telephone number and e-mail.
After receiving the identification information the Company’s staff should verify this information requesting the appropriate documents. Appropriate documents for verifying the identity of customer include, but are not limited to, the following:
- For an individual customer: A high resolution scanned copy or photo of pages of a passport or any other national ID, indicating family name and name(s), date and place of birth, passport number, issue and expiry dates, country of issue and Client’s signature.;
To verify proof of address of the customer the Company requires one of the following to be provided with:
- A high-resolution copy of a utility bill (fixed-line phone, water, electricity) issued within the last 3 months; or
- A copy of a bank statement (for a current account, deposit account or credit card account); or
- A copy of a bank reference letter.
If an existing customer either refuses to provide the information mentioned above or if a customer has purposely given false information, the Company will consider closing the account of an existing
customer after assessing the risks involved. Measures under the Regulations require more study and detection of clients who could pose a potentially high risk of funding money laundering/terrorism. For all contractual relationships with clients, the Company will perform continuous customer due diligence and account tracking. In particular, the company’s understanding of what its customers are doing, the degree of danger they pose, and whether something is inconsistent with knowledge or views previously held about the customer, is periodically checked and refreshed.
AML Compliance Officer
The Company shall appoint an AML Compliance Officer, who will be fully responsible for the Company’s AML and CFT program and report to the Board of the Company or a committee thereof any material breaches of the internal AML policy and procedures and of the Regulations, codes and standards of good practice.
AML Compliance Officer’s responsibilities include:
a) Ensuring the Company’s compliance with the requirements of the Regulations;
b) Establishing and maintaining internal AML program;
c) Establishing an audit function to test its anti-money laundering and combating the financing of terrorism procedures and systems;
d) Training employees to recognize suspicious operations;
e) Ensuring that proper AML records are kept;
f) Obtaining and updating international findings concerning countries with inadequate AML systems, laws or measures.
All staff, managers and directors of the company must know this policy. Employees, executives and directors involved in AML-related roles must be properly vetted. Any breach of this policy or of an AML program must be reported to the AML Compliance Officer in confidence, unless the breach concerns the AML Compliance Officer, in which case the employee must report the breach to the Chief Executive Officer.
Employee Training Program
The Company provides AML training to employees who will be dealing with customers or will be involved in any AML checking, verification or monitoring processes. The Company may conduct its training internally or hire external third party consultants.
In relation to all policies, procedures, customer documentation forms and specifications, each person working within the Company is assigned a supervisor who teaches him or her. The Company’s AML training programs are structured to ensure that its staff receive sufficient standards of training with respect to any potential AML/TF threats.
Content of training
The Company’s AML and risk awareness training includes the following content:
- The Company’s commitment to the prevention, detection and reporting of ML and TF crimes.
- Examples of ML and TF that have been detected in similar organizations, to create an awareness of the potential ML and TF risks which may be faced by the Company’s employees
- Well known or recognized typologies, especially where made available by the FATF or AML Supervisors.
- The consequences of ML and TF for the Company, including potential legal liability.
- How to identify and report unusual activity that may be a suspicious transaction or attempted transaction.