Model Compliance Programme for Accountants.doc

102 ithe compliance officer will periodically assess

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10.2 I/The Compliance Officer will periodically assess the risk of criminal conduct and take appropriate steps to design, implement or modify its compliance program to reduce the risk of criminal conduct identified through this process. 11 Independent Audit 11.1 I/Entity XXX agree (s) that I/it will ensure that an internal audit/ review of the application, compliance, enforcement, appropriateness and effectiveness of the Compliance Program is conducted annually. The results of this internal review will be a written report kept on Page | 24
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file/submitted to the Members of the BOD for consideration which will include suggestions for improvement for determination and decision. The person(s) responsible for this internal review must be independent from the implementation of the procedures and the processing of business transactions and independent from the compliance function. 11.2 I/Entity XXX also agrees that it will ensure that an external audit/ review is conducted to evaluate compliance with the relevant legislation and guidelines The results of this external review will be a written report which includes recommendations to be submitted to the Members of the BOD and the FIU for consideration. The person(s) responsible for this external review must be independent Entity XXX. Page | 25
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APPENDICES Appendix I - Know Your Customer Form Date INDIVIDUAL CUSTOMER INFORMATION Name (First Name, Middle Name, Surname) Date of Birth National Identification No./DP No./Passport No. Address Country of Birth Business/Residence Phone No. Copy of Utility Bill Attached: Yes/ No Local Resident: Other : obtain Bank reference Letter Occupation/ Nature of Business Occupational income: Purpose of transaction/ intended nature of business relationship/ transaction: Any other information: Signature Date: CORPORATE CUSTOMER INFORMATION Name of Business Country of Incorporation Registered Office/ Address Signed Directors Statement outlining the nature of the Company’s business Purpose of transaction/ intended nature of business relationship/ transaction: Beneficial owners Secretary Directors/ Officers/ Partners Copies of ID for 2 Directors obtained: Copies of POA BOD Resolutions Articles of Incorporation/ Continuance; Certificate of Incorporation/ Continuance Company By Laws/ Partnership Deed Management Accounts for 3 years or other proof of source of funds to be used ID of shareholders with more than 10% Confirm US 1267 List Checked: Any other information: OTHER CONSIDERATIONS Page | 26
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Political Exposed Person (PEP): Are you : (i ) a current or former senior official in the executive, legislative, administrative or judicial branch of a foreign government, whether elected or not (ii) a senior official of a major political party (iii) a senior executive of a foreign government-owned (iv) commercial enterprise (iv)a senior military official (v)an immediate family member of a person mentioned in paragraphs (i) to (iv) meaning the spouse, parents, siblings or children of that person and the parents, siblings and additional children of the person's spouse Establish source of wealth Obtain senior management approval
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