Anti Money Laundering (“AML”) and Counter Terrorist Financing (“CTF”) Policy

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 firms through which they attempt to launder criminal proceeds without the firm’s knowledge or suspicions.

In response to the scale and effect of money laundering, Switzerland has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for Swiss firms and outline the offences and penalties for failing to comply.

We are subject to provisions on Anti Money Laundering (AML) under the laws of Switzerland, which are in accordance with the FATF recommendations. Switzerland is a member country of the Financial Action Task Force FATF). This means in particular that we have to identify its customers and establish the beneficial owner’s identity. The AML compliance policies approved by the Management Board include inter alia the processes for the identification of the customers and establishing the identity of the beneficial owner. The policies also cover the collection of information regarding the customers’ business activities, relationships with Politically Exposed Persons and record retention procedures. Furthermore, we regularly provide AML training to relevant employees and does not provide banking services to any bank that does not maintain a physical presence in any country and that is not a regulated affiliate. The anti-money laundering policies are applicable to head office and branches alike and are in accordance with the Wolfsberg anti-money laundering principles.

The fight against money laundering and terrorist financing

As a self-regulatory organisation (SRO) approved by FINMA, Surveillance pour Intermédiaires Financiers & Trustees (“SOFIT”)  ensures the respect by its members of the Federal Act on Combating Money Laundering and Terrorist Financing in the Financial Sector (MLA) in the following areas.

  • asset and fund management
  • exchange and money transfer
  • company administration, trusts
  • payment services
  • credit, leasing and factoring
  • lawyers and notaries
  • insurance brokerage

Anti-Money Laundering (AML) Policy:

Our AML Policy is designed to prevent money laundering by meeting the Swiss AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

  • The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
  • Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
  • Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
  • Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
    Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
  • The maintenance of appropriate records for the minimum prescribed periods;
  • Training and awareness for all relevant employees

Sanctions Policy:

We are prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. We will therefore screen against the relevant sanctions lists in the jurisdictions in which we operate.

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