MONEY TRANSFERS

AML Policy

1. INTRODUCTION:

This manual will provide you with a guide to your obligations under the UK anti-money laundering laws in connection with Money Transfer and our Bureau De Change business. All Money Service Businesses (MSBs, which include a Bureau de Change & Money Transmission Agents) have to comply with the Terrorism Act 2000, Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017. Compliance with the regulations is policed by Revenue & Customs:

A) Requiring any attempt to acquire Criminal property to be reported to NCA

B) Imposing conditions upon transactions that are happening in the future

C) Extending the failure to report offenses to include negligent failure to report.

In addition, HM Treasury Asset Freezing Unit lists individuals with whom it is a criminal offense to conduct a transaction. MT Global Ltd, checks all transactions against this list. It is vital that you comply with the Terrorism Act 2000, Money Laundering Regulations 2017, and the Proceeds of Crime Act 2002.

The Purpose of these guidelines is to ensure that you:

A) Understand the importance of the money laundering laws and regulations;

B) Understand and have in place the required preventive controls;

C) Know how to recognize a suspicious transaction; and

D) Know what to do should such a suspicious transaction arise

These guidelines provide an explanation of the procedures and requirements you, as an agent of MT Global Limited are expected to follow.

2. What is Money Laundering?

Money laundering is the process by which criminally obtained money or other assets are exchanged for "clean" money or other assets which no obvious link to their criminal origins. It is often associated with drug dealing, fraud, organized crime, tax evasion or terrorist financing. If undertaken successfully it will allow criminal to maintain control over the proceeds & ultimately to prove a legitimate cover for their source of income.

3. Money Laundering Regulations

2017 Money Laundering Regulations place a range of obligations on MSB‟s: Requirement to be registered as an MSB with the designated regulator (HMRC). Requirement for those who run money transfer companies to satisfy “fit & proper‟ test (those not judged satisfactory will be prohibited from running money service businesses). Customer “due diligence” requirements obligation to identify the customer & verify the customer from an independent data source.

Special due diligence obligations in three specific situations:

▣   For non-face to face customers, customers who may be “politically exposed” or customers who may present a higher risk of money laundering.

▣   Beneficial ownership obligations to understand who are underlying individuals who make financial gains from business relationships or transactions

▣   When a business relationship has been established, requirements to establish customer source of funds/purpose of transaction, also on going monitoring obligations

To keep business records for 5 years

To have internal reporting mechanisms to allow reporting of suspicious activity

To appoint a Nominated Officer (sometimes known as Money Laundering Reporting Officer

To train staff on the law and training in how to recognize suspicious activity

To take a “risk based approach‟ to all aspects of the AML policies for the business

Penalties: Criminal conviction under the MLR‟s can incur up to 2 years imprisonment. HMRC has powers to impose civil penalties (fines) on business that fail to comply with the MLR‟s in respect of: Notification and registration requirements, Customer due diligence measures, Record-keeping

Policies and procedures to forestall and prevent money laundering and terrorist financing

Disclosures under Part 7 of the Proceeds of Crime Act Training of employees.

Regulator: HM Revenue. Fines will be for an amount that is considered by supervisory authority appropriate for purposes of being effective, proportionate & dissuasive‟.

4. EU Payments Regulation

The definition of money laundering corresponds to the one in Directive (EU) 2015/849 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC 2005/60/EC and is internationally recognized. For the purposes of this Directive, the following conduct, when committed intentionally, shall be regarded as money laundering.