Model Compliance Programme for Accountants.doc

Aml cft program was developed and was approved by

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AML/ CFT Program was developed and was approved by Entity XXX. While the task of detecting crime falls to law enforcement agencies, requests may be made on occasion or, under due process of law, mandates may be received to assist law enforcement agencies in that task and as such, the duty of vigilance is necessary to avoid assisting the process of money laundering and to react to possible attempts at being used for that purpose. 2.4 The duty of vigilance consists mainly of the following: (a)Appointment of a Compliance Officer at senior management level (b)Implementation of an AML/ CFT Compliance Program Page | 4
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(c) Verification of identification and other information (d)Performance of due diligence procedures on suspicious activities/transactions (e)Reporting of suspicious activities or transactions (f) Maintenance and retention of all relevant records (g)Facilitation of training programs (h)Implementation of a system of internal controls to ensure ongoing compliance 2.5 This document constitutes the compliance program (“Compliance Program”) of name of accountant/Entity XXX, which is required under the various AML/ CFT legislation, regulations and guidelines for qualifying entities/ persons to implement and to obtain the approval of the Financial Intelligence Unit (“FIU”). 2.6 Section 28 (1) of the FIU Regulations requires all qualifying Accountants (i.e. those performing the relevant business activities mentioned in Section 1.2 above) to register with the FIU within three (3) months of the FIU Regulations coming into force. These Regulations became effective on 8 February 2011. 2.7 Section 31 (1) of the FIU Regulations requires all qualifying Accountants to submit its Compliance Program to the FIU within three (3) months of the FIU Regulations coming into force. These Regulations became effective on 8 February 2011. 2.8 I am aware of/ All members of staff in receipt of a copy of the Compliance Program must sign a form provided to them at the time of receipt of said copy of the Compliance Program indicating that they understand my/their obligations and duties as contained herein. 3. Overview of Money laundering and Financing of Terrorism Crimes Money laundering is the process of concealing or disguising the existence, source, movement, destination or illegal application of illicitly derived property or funds to make them appear legitimate. It usually involves a three part system: Placement of funds into a financial system, layering of transactions to disguise the source, ownership and location of the funds, and integration of the funds into society in the form of holdings that appear legitimate. The three states are explained further as follows: Page | 5
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A. Placement –the physical disposal of cash or other assets derived from criminal activity. During this phase, the launderer introduces the legal proceeds into the system. This can be achieved by circulation through financial institutions, casinos and other businesses both domestic and international. This phase can involve breaking up of large amounts of cash into smaller ones and
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