The Company protects itself from involvement in money laundering or suspicious activity by the following means:
- Performing an enterprise-wide risk assessment to determine the risk profile of the Company
- Establishing AML policies and procedures
- Implementing internal controls throughout its operations that are designed to mitigate risks of money laundering
- Performing know your customer (“KYC”) procedures on all Clients
- Designating a Compliance Officer with full responsibility for the AML Program
- Conducting frequent AML audits through auditors appointed by the the Financial Services Standards Association (VQF).
- Providing AML training to all employees
POLICIES AND PROCEDURES
The Policy will be approved by the Company’s Board. The Policy once approved will be provided to all employees. Each employee will acknowledge the Policy in writing. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.
The Company has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with all AML legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the Customer Identification Program, the Suspicious Activity Reporting system, and the required reports on the Program’s effectiveness to the Board.
All of the officers and employees of the Company are required to receive AML training according to stipulations from the Financial Services Standards Association (VQF) and the Eidgenössischen Finanzmarktaufsicht” (The Swiss Financial Supervisory Authority – FINMA).
The Company will track the training progress of all employees and maintain documentation of each employee, the date of the AML training as well as a description of such training. New employees will receive appropriate AML training within 30 days of their hire date. Training for all employees will include not only the legal elements of AML laws and regulations but will also cover job specific applications of these laws. Ongoing training will be provided and updated regularly to reflect current developments and changes to laws and regulations.
The Company has appointed a Compliance Officer to be responsible for the management, coordination and monitoring of compliance with this policy and all applicable AML laws and regulations. The Compliance Officer will have a working knowledge of all AML laws and be qualified by knowledge, experience and training. The Compliance Officer will be responsible for filing (if applicable) or keeping a record of suspicious transaction reports (“STR”) and suspicious activity reports (“SAR”) with the appropriate agencies and for overseeing the annual audit. The Compliance Officer will oversee all corrective action of any audit findings or other AML-related issues. The Compliance Officer will be responsible for all record keeping requirements and provide reports on the effectiveness of the AML program to the Company’s Board.