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Preventing Financial Crime: Group Policies and Procedures

The Group has established comprehensive policies and procedures to prevent financial crime. These measures are designed to ensure that the Group identifies, assesses, and manages Financial Crime risk effectively and in accordance with applicable regulations.

1. Due Diligence Measures

The Group must perform due diligence measures on customers and third parties before establishing a relationship and throughout its duration.
Due diligence measures must be completed prior to carrying out transactions on behalf of the customer or entering into a contract with a third party.

2. Financial Crime Risk Assessment

The Group must assess the Financial Crime risk associated with customers, third parties, and Associated Persons of the Group before establishing a relationship.
Enhanced due diligence measures must be applied to relationships that pose an increased risk of financial crime.

3. Authentication Framework

The Group must establish an authentication framework to ensure that all customer interactions have necessary verifications to provide confidence that customers are who they claim to be.

4. List Management Framework and Governance

The Group must maintain a list management framework and governance to identify, assess, and manage the Financial Crime risk exposure associated with geography and industries for customers and third parties.

5. Prohibited Relationships

The Group must not establish or maintain relationships where it cannot obtain sufficient information or mitigate the Financial Crime risks associated with the customer or relevant parties.

The Group must develop and maintain procedures and processes for sharing information within the Group to prevent financial crime.