Anti-Money Laundering (AML) Compliance policy
The Zeal forex bureau AML Policy is designed to prevent money laundering by meeting the Ugandan and international AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the company being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be adhered to.
Zeal Forex Bureau is committed to the highest standards of anti-money laundering (AML) and counter terrorism financing (CFT ), and requires management and employees to adhere to these standards so as to prevent the use of its products and services for any Money laundering purpose.
Zeal Forex Bureau examines its AML strategies and objectives on an ongoing basis, and maintains an effective AML policy that reflects its best practices as a domestic financial services provider.
Zeal forex bureau AML program includes appropriate KYC and Customer Acceptance policies, including establishing the identity of the true beneficial owners, adherence to all legal and regulatory requirements imposed by the government and its regulators.
Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income.
Criminals specifically target financial services firm, companies or institutions through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.
Anti-Money laundering refers to controls required of financial institutions and other regulated entities to prevent, detect and report money laundering activities.
It’s the process by which criminals attempt to conceal the true origin and ownership of the proceeds of their criminal activity, allowing them to maintain control over the proceeds and ultimately, proving a legitimate cover for their source of income
It can also be referred to as “cleaning of money” in money laundering process, illegally obtained money is given the appearance of having originated from a legitimate source.
STATEMENT OF POLICY .
1. The company supports the fight against money laundering and terrorism by adopting this AMLCompliance Policy to prevent the Agent’s financial services from being used to promote such criminal activity.
2. Cooperate with all the authorities, to the extent that is permitted by applicable Laws, so as to help them in their efforts to prevent or fight money laundering, and the financing of terrorism proliferation.
3. The company will fully comply with both the intent and letter of all laws and regulations relating to AML, the prevention of terrorist financing and economic sanctions
4. The Agent will train its employees to comply with these laws and regulations.
5. Every employee of the company who conducts or is involved in a Money Service Business (MSB) operation is required to understand and comply with the contents of this document.
6. A copy of this AML Compliance Policy will be kept at each location conducting money services, in a place that is accessible to all employees conducting MSB and forex transactions.
7. Maintain all customer/transactions related records for at least 10 years or for longer period if the Law in the country requires so.
THE COMPLIANCE OFFICER
Gondha Tonny Is here by designated as the Anti-Money Laundering Compliance Officer.
COMPLIANCE OFFICER RESPONSIBILITIES
EMPLOYEE TRAINING REQUIREMENTS
Zeal Forex Bureau follows a rigid recruitment process, part of it being the mechanism of understanding any relationship of potential employees with any kind of crime/criminal activities.
Within our induction program, which consists of a number of intensive and hands-on training sessions, Zeal Forex Bureau trains the newly recruits in the principles, methodologies, policies and procedures of AML/KYC. Training on AML/KYC
Policy and Procedures is an ongoing procedure in Zeal Forex Bureau, with refresher training offered to all its employees every month at a minimum.
Training is to be provided to all employees (new and existing) before conducting MSB/forex transactions, and, at a minimum, must include:
All training will be documented and retained in employee personnel files, other related AML files, or with the Training Log in the TRAINING RECORDS section of the Compliance Training Resource. An employee will also receive additional AML training in the event of a performance issue related to an AML incident.
KNOW YOUR CUSTOMER (KYC) PROCESS
One of the most effective ways to protect the business from becoming the victim of financial crimes starts with confirming the identity of the customers and knowing with whom money service/forex transactions are being conducted. To avoid processing transactions that could put the company at risk, the company will implement a ‘Know Your Customer (KYC)” process that includes, but is not limited to:
VALIDATING PHOTO IDENTIFICATION
(Photo Required) The photo ID must be issued by a legitimate issuing body.
The customer’s name and likeness must match the information and picture on the photo ID.
If the customer is not a resident of UGANDA, he / she must present a passport, or other official document evidencing nationality or residence and Zeal forex bureau employee should try and contact the issuing authority to confirm authenticity of the identification.
The COMPANY will not accept any form of identification that has expired or appears to be altered or fabricated.
ACCEPTABLE FORMS OF CUSTOMER ID (but may not be limited to :)
CASH PURCHASE/SALE OF FOREX TRANSACTIONS.
Multiple forex cash purchases/sale made by the same person in one business day must be aggregated, or added together, and treated as a single purchase/sale, even if purchased or sold at different times during the day.
Whenever the same consumer/customer purchases or sells $5,000 or more in forex, using cash, in the same day, you MUST obtain and record the following consumer transaction information on the large cash transaction BEFORE completing the transaction(s)
Name and physical/postal Address of location of the
All information must be obtained from the customer and documented BEFORE processing the transaction on the Money Business and forex transaction system.
Total Amounts More Than $10,000
Amounts more than $10,000 also requires a counter terrorism financing CTR to be E-Filed at www.fia.co.ug Information must also be recorded on the Money Order Transaction Log as detailed above.
PROCESSING SEND TRANSACTIONS
BEFORE processing any Money transfer send transaction, the company employee must:
The Agent may require a customer to provide additional identifying information BEFORE completing any money services transaction depending on the type, amount, or circumstances surrounding the transaction.
CONFIRMING THE CUSTOMER ID INFORMATION:
BEFORE processing any money transfer send transaction, the company employee must:
RECORD THE APPROPRIATE CUSTOMER ID INFORMATION:
Please refer the customer ID Requirements posted on the Money service business Counters.
Ensure all the necessary details are well documented.
If a customer refuses to provide any information required, the company CANNOT process the transaction.
PROCESSING MONEY TRANSFER RECEIVE TRANSACTIONS
BEFORE conducting any money transfer receives transaction, the company employee will:
Regardless of the amount, you SHOULD CONFIRM THE GENUINITY OF THE ID WHEREEVER POSSIBLE .
The company employees MUST require a customer to provide personally identifying information BEFORE completing any money service receive transaction.
Please refer the Customer ID Requirements posted on the MoneyGram, express and western union Counter.
If a customer refuses to provide any information required the Agent/company CANNOT process the transaction.
Maintenance of Records
Management and Controls of AML
Adherence to the company AML program needs to be reviewed regularly to ensure that the Company’s efforts are successful. AML Officers in Zeal forex bureau are therefore obliged to conduct appropriate controls. The responsible AML Officer must ensure, by implementing adequate customer- and business related controls that are applicable AML requirements are being adhered to and security measures are properly functioning.
Zeal has implemented a strict KYC program to ensure all kinds of customers (natural or legal persons or legal structures, ) are subject to adequate identification. This program has been implemented in all branches.
KYC includes not only knowing the clients deals with (either as a single transaction or ongoing relationship), or renders services to, but also the Ultimate Beneficial Owners
The program includes strict identification requirements, name screening procedures and the ongoing monitoring and regular review of all existing business relationships.
Zeal forex bureau has implemented a comprehensive AML training program to ensure that all staff and particular individuals responsible for transaction processing, initiating or establishing business relationships, undergo AML awareness training.
Zeal training is tailored to the business to ensure that staffs are aware of different possible patterns and techniques of money laundering which may occur in their everyday while transacting business.
Processes to ensure staff reliability
Zeal forex bureau has implemented processes to ensure that only reliable individuals are employed for example through referrals from high ranking individuals, obtaining police/Interpol letter, copies of academic documents, letter from previous employer if any, hand written application ,curriculum vitae and passport size photos.
Anti-Bribery and Corruption (ABC) .
Zeal does not tolerate bribery, or any form of corruption. All Zeal forex bureau employees and third parties that act on its behalf are strictly prohibited from having any involvement in acts of bribery and corruption.
MONEY LAUNDERING – CONCLUSION
IF YOU WANT TO GO FAST, GO ALONE, IF YOU WANT TO GO FAR GO TOGETHER,