1.0 Policy Summary
M&C Logistics And Trading Limited is committed to conducting its business in accordance with all applicable laws and regulations, and in a way that enhances its reputation in the Gold industry. This policy records our approach to the identification, mitigation, and management of the risk that our products and services might be involved in the facilitation of money laundering or the financing of terrorism.
2.0 Description of Money Laundering and Terrorism Financing
Money Laundering (“ML”)
An activity which is designed to conceal or disguise the true origin of criminally derived proceeds in order to make them appear to have been sourced from legitimate sources.
Terrorist Financing (“TF”)
Considered to be the act of providing financial support to terrorism or terrorist organizations to enable them to carry out acts of terrorism.
3.0 Objectives
M&C Logistics And Trading Limited has established an AML/CTF policy which sets the core principles for the management of ML/TF risk. The policy is global in nature and outlines groupwide standards to meet regulatory and ethical obligations in the economies in which we do business. This contributes to the stability, integrity, and strength of the Gold Supply Chain and protects M&C Logistics and Trading Ltd from reputational damage and regulatory action. The Policy is subject to regular review to ensure it remains current with regulator expectations and industry standards.
4.0 Our Core Principles
M&C Logistics And Trading Limited has adopted the following core principles:
- Oppose the crimes of money laundering and terrorist financing and maintain a framework to identify and mitigate the risk that its products and services could be used for such purposes.
- Report any activity that it detects which is suspicious and may involve potential money laundering or terrorism financing to the applicable regulator.
- Comply with the AML/CTF laws, rules, and regulations of the countries in which we provide our services to.
- Endeavor to provide its products and services only for legitimate purposes to customers whose identities have been reasonably ascertained.
- Take reasonable steps to ensure that sufficient resources are available for the implementation and performance of activities required by our AML/CTF Program.
- Require employees to attend AML/CTF training to understand their obligations under the relevant laws, rules, and regulations.
- Monitor its customers, their transactions, and its employees, consistent with the level of money laundering and terrorist financing risk they represent.
- Make changes to our services, business processes, and systems to ensure that money laundering and terrorist financing risks are identified and managed.
5.0 Know Your Customer (“KYC”)
M&C Logistics And Trading Limited endeavors to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYC policies and procedures to establish and verify the identity of customers will also be complied with. These include:
- Customer acceptance procedures that identify types of customers and transactions likely to pose a higher than average risk to the company and require a higher level of due diligence.
- Procedures to establish if customers are known or suspected money launderers, terrorists, or otherwise engaged in criminal activity (e.g., reviewing customers against government/United Nations/regulators’ lists of proscribed persons).
- Enhanced Due Diligence undertaken where a transaction or a counterparty results in a heightened level of financial crime or reputational risk.
- A risk-based periodic review of existing customer records to maintain currency and completeness.
- Ongoing monitoring of transactions conducted by customers using a risk-based approach.
- Procedures prohibiting accounts/relationships, including payment processing, with shell banks.
- A clear statement on what records must be kept on customer identification and individual transactions and their retention period.
- Regular compliance reviews and audits of AML/CTF program and procedure documents and execution against established standards.
6.0 Suspicious Activity
Our staff are trained and made aware of “red flags”, or anything that is unusual or out of the ordinary when dealing with customers and customer-related information. The company has the relevant procedures and processes in place to ensure that any genuinely suspicious matters are detected and escalated for review by senior management.
7.0 AML/CTF Training Program
M&C Logistics And Trading Limited has a robust AML/CTF Training Program to educate employees in implementing and maintaining the company’s AML/CTF Program. All employees undergo initial AML/CTF training when they join the company. In addition, there are ongoing training requirements for all employees.
