1. Purpose
The purpose of this Anti-Money Laundering (AML) Policy is to establish a framework to ensure that OFMCorp Ltd complies with applicable anti-money laundering regulations and to mitigate the risk of the firm being used for money laundering activities. This policy outlines the procedures for detecting and reporting suspicious activities.
2. Scope
This policy applies to all employees, consultants, and contractors of OFMCorp Ltd (hereinafter referred to as "the Firm").
3. Definitions
- Money Laundering: The process of concealing the origins of money obtained through illegal activities.
- Suspicious Activity: Any transaction or behavior that deviates from the norm and suggests the possibility of money laundering.
4. Roles and Responsibilities
- Compliance Officer: The Compliance Officer is responsible for overseeing AML efforts, including the implementation and maintenance of the AML policy, training employees, and ensuring compliance with all relevant laws and regulations.
- Employees: All employees are responsible for adhering to the AML policy, identifying suspicious activities, and reporting them to the Compliance Officer.
5. Customer Due Diligence (CDD)
The Firm will conduct due diligence on all clients to assess and manage the risk of money laundering. This includes:
- Identifying Clients: Collecting and verifying identification information for all clients.
- Risk Assessment: Assessing the risk profile of each client based on factors such as the nature of the business, geographical location, and transaction patterns.
- Ongoing Monitoring: Continuously monitoring client transactions to identify and report suspicious activities.
6. Record Keeping
The Firm will maintain records of all transactions and due diligence documentation for a minimum of five years. Records must be readily available for inspection by regulatory authorities.
7. Reporting Suspicious Activities
- Internal Reporting: Employees must report any suspicious activity to the Compliance Officer immediately. The report should include details of the suspicious activity and any relevant documentation.
- External Reporting: The Compliance Officer will evaluate the internal reports and, if deemed necessary, file a Suspicious Activity Report (SAR) with the relevant authorities.
8. Training and Awareness
All employees will receive training on the AML policy and procedures. Training will be conducted annually and will cover:
- The importance of AML compliance.
- How to identify and report suspicious activities.
- Updates on relevant laws and regulations.
9. Internal Controls and Audit
The Firm will establish internal controls to ensure compliance with the AML policy. This includes:
- Regular audits to assess the effectiveness of the AML policy and procedures.
- Reviewing and updating the AML policy as necessary to reflect changes in regulations and business practices.
10. Confidentiality
All reports of suspicious activities and client information must be kept confidential. Unauthorized disclosure of such information is strictly prohibited and may result in disciplinary action.
11. Policy Review
This AML policy will be reviewed annually by the Compliance Officer and updated as necessary to ensure its effectiveness and compliance with applicable laws and regulations.
12. Approval and Implementation
This policy is approved by the Board of Directors and is effective as of 01.06.2024. All employees are required to acknowledge and adhere to the policy.
OFMCorp Ltd
Date: 01.06.2024
By adhering to this AML policy, OFMCorp Ltd commits to maintaining the highest standards of integrity and compliance in all its operations.