1. Introduction: Explain the purpose and importance of the AML policy.
2. Legal Framework: Outline relevant international, national, and regional AML laws and regulations.
3. Risk Assessment: Detail the process for assessing and mitigating money laundering risks associated with H Global Trade’s operations.
4. Customer Due Diligence (CDD): Describe procedures for verifying the identity of customers, including enhanced due diligence for high-risk customers.
5. Monitoring and Reporting: Explain how transactions will be monitored for suspicious activity, and detail the process for reporting such activity to appropriate authorities.
6. Employee Training: Specify the training programs provided to employees to ensure compliance with AML regulations.
7. Record-keeping: Outline requirements for maintaining records of customer transactions and AML compliance efforts.
8. Internal Controls and Procedures: Detail internal controls and procedures implemented to prevent money laundering.
9. Sanctions Compliance: Ensure compliance with sanctions regulations, including screening customers against relevant sanctions lists.
10. Compliance Officer: Appoint a compliance officer responsible for overseeing AML efforts and ensuring compliance with regulations.
11. Penalties for Non-Compliance: Clearly state the consequences of failing to comply with the AML policy, including disciplinary actions and legal consequences.
12. Review and Update: Establish a process for regularly reviewing and updating the AML policy to reflect changes in regulations or business practices