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Anti-Money Laundering (AML) and Combating the Financing of Terrorism (CTF) Program Policy

This comprehensive policy outlines The TKB’s commitment to preventing and detecting money laundering (ML) and combating the financing of terrorism (CTF).

I. Compliance Structure

• A dedicated AML & CTF Compliance Officer is responsible for implementing this policy.
• The Chief Compliance Officer has overall responsibility for ensuring compliance with all relevant laws, regulations, and standards.

II. Record Keeping

• All relevant records, including transactional records and customer identification documents, must be retained for at least 6 years after the completion of a transaction or the closure of an account.
• The TKB will maintain accurate and detailed records to facilitate effective monitoring and compliance.

III. Risk Assessment

• The TKB will review its business operations to identify potential ML/TF risks.
• Additional procedures will be designed and implemented to mitigate and manage these risks, ensuring the effectiveness of our AML/CTF program.

IV. Reporting Requirements

• Suspicious transactions must be reported to the Financial Services Unit (FSU) immediately.
• The AML & CTF Compliance Officer is responsible for investigating suspicious transactions before reporting them to FSU.

V. Cooperation with External Authorities

• The TKB will cooperate fully with external authorities, including FSU, and comply with any directions or notices received from these bodies.
• We recognize the importance of collaboration in preventing ML/TF and will maintain open communication channels with relevant stakeholders.

VI. Feedback Mechanism

• The AML & CTF Compliance Officer will take all necessary steps to implement feedback, notices, orders, warrants, etc., issued by FSU.
• Any feedback provided by FSU must be shared with the Chief Compliance Officer and incorporated into ongoing monitoring programs, ensuring continuous improvement of our AML/CTF program.