AML Policy

Introduction

Falah Fintech Limited is committed to the highest standards of compliance with AML, CTF, and CPF regulations. The company has established robust controls to prevent money laundering, terrorist financing and proliferation financing, ensuring all transactions adhere to legal requirements. A Money Laundering Reporting Officer (MLRO) oversees compliance efforts, and staff is thoroughly trained in AML protocols.

Key Concepts

• Money Laundering (ML): The process of disquising the origin of illegal money to make it appear legitimate, typically involving placement, layering, and integration stages.
• Terrorist Financing (TF): The collection or provision of funds to support terrorist activities, which can involve both legal and illegal sources.
• Proliferation Financing (PF): The provision of funds or financial services for the proliferation of weapons of mass destruction (WMD).

Regulatory Compliance and Framework

Falah Fintech Limited adheres to several key pieces of legislation, including:

• The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017: Mandates businesses to establish effective systems and controls to prevent money laundering and terrorist financing.
• Proceeds of Crime Act 2002 (POCA): Defines offenses related to money laundering.
• Terrorism Act 2000: Addresses offenses related to terrorist financing.
• Sanctions and Anti-Money Laundering Act 2018 (SAMLA): Provides a legal basis for implementing sanctions regimes.
• FCA and HMRC Guidelines: Offer guidance on managing financial crime risks.

The policy underscores the importance of complying with these regulations, ensuring that Falah Fintech Limited’s operations remain lawful and transparent.

 

Anti-Money Laundering Policy Objectives

Falah Fintech Limited's AML policy has several key objectives:

1. Compliance: Ensuring full adherence to relevant UK AML regulations.
2. Risk Management: Establishing a risk-based approach that focuses on identifying, assessing, and mitigating risks.
3. Prevention and Detection: Implementing effective controls and procedures to prevent and detect money laundering, terrorist financing, and proliferation financing.
4. Reporting: Ensuring all employees understand their obligations to report suspicious activities promptly to the relevant authorities.
5. Training: Providing ongoing training and awareness programs to equip employees

 

Governance and Compliance Structure

Falah Fintech Limited has established a robust governance structure to oversee its AML, CTF, and CPF efforts. The company’s governance framework includes:

• Money Laundering Reporting Officer (MLRO): The MLRO, our Officer is responsible for overseeing the company’s AML and CTF compliance efforts. He ensures adherence to relevant regulations and manages risks associated with money laundering and terrorist financing. The MLRO is also the primary point of contact with regulatory authorities and law enforcement agencies.
• Nominated Officer: The Nominated Officer is responsible for receiving disclosures under the Proceeds of Crime Act 2002 and the Terrorism Act 2000. This officer assesses whether reports of suspicious activities should be forwarded to the National Crime Agency (NCA).
• Compliance Officer: The Compliance Officer ensures adherence to regulatory requirements and maintains financial integrity. This officer is responsible for conducting risk assessments, providing training to employees, and overseeing transaction monitoring and reporting.

 

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

The policy mandates rigorous Customer Due Diligence (CDD) procedures for all customers. These procedures include verifying the identity of customers, understanding the nature of their transactions, and assessing the risks associated with each customer relationship. For high-risk customers, such as Politically Exposed Persons (PEPs) or customers from high-risk jurisdictions, Enhanced Due Diligence (EDD) is required. This includes additional verification measures and more frequent monitoring of transactions.

Transaction Monitoring and Reporting

Falah Fintech Limited employs a robust transaction monitoring system to identify and evaluate transactions that may indicate suspicious activity. This system is designed to detect deviations from established transaction patterns, identify transactions involving high-risk countries, and screen for associations with individuals or entities on sanctions lists. All suspicious activities must be reported to the NCA via a Suspicious Activity Report (SAR), and employees are trained to avoid "tipping off" customers, which could jeopardize investigations.

Staff Training and Awareness

The policy emphasizes the importance of ongoing staff training and awareness. Employees are trained to recognize suspicious activities, understand their reporting obligations, and stay updated on AML regulations. Training is provided at the start of employment and regularly thereafter, with records of training activities maintained for compliance purposes.

Data Protection and Record-Keeping

Falah Fintech Limited is committed to complying with the Data Protection Act (DPA). The policy ensures that personal data is processed fairly, lawfully, and securely. Records of customer identities, transaction details, and suspicion reports are retained for at least five years, in line with the requirements of the Money Laundering Regulations 2017. The company also has strict procedures for the international transfer of personal data to ensure compliance with data protection laws.

Data Protection Officer

In compliance with the General Data Protection Regulation (GDPR), we have appointed a Data Protection Officer (DPO) to ensure that our organization meets its obligations under data protection laws. The DPO’s role includes monitoring compliance with the GDPR, providing guidance on data protection impact assessments, and acting asa point of contact between our organization and data protection authorities. The DPO is also responsible for addressing any concerns or inquiries regarding the processing of personal data.

Conclusion

Falah Fintech Limited's AML, CTF, and CPF policy is a cornerstone of its commitment to regulatory compliance and ethical business practices. By implementing a comprehensive compliance framework, the company not only protects its operations but also upholds its responsibilities to customers and the broader financial system. Through continuous monitoring, regular staff training, and strict adherence to regulations, Falah Fintech Limited ensures that it remains a trusted and compliant entity in the financial services sector.