Anti-Money Laundering Policy
Introduction
FINSAI TRADE LTD. is registered by the International Services Authority of Nauru with company registration number 003112024 and with Brokerage License number 052943-033 operating under the trading name Finsai Trade (hereinafter “The Company”).
The Company has implemented policies, controls and procedures in line with the Financial Intelligence Centre Act, No 38 of 2001 (The FIC Act) together with the Prevention of Organized Crime Act, 1998 (POCA), the Prevention and Combatting of Corrupt Activities Act, 2004 (PRECCA) and the Protection of Constitutional Democracy Against Terrorist and Related Activities Act, 2004 (POCDATARA) under the guidance on how to comply with these requirements. The phrase “money laundering” covers all procedures to conceal the origins of criminal proceeds so that they appear to originate from a legitimate source. The Company aims to detect, manage and mitigate the risks associated with money laundering and the financing of terrorism.
The Company has introduced strict policy aimed on the detection, risk prevention or mitigation in respect of any suspicious activities performed by Clients.
The Company is required to constantly monitor its level of exposure to the risk of money laundering and the financing of terrorism.
The Company believes that if it knows its Clients well and understands their instructions thoroughly, it will be better placed to assess risks and spot suspicious activities.
Client Acceptance Policy
Effective Client Due Diligence (”CDD”) measures are essential to the management of money laundering and terrorist financing risk. CDD means identifying the Client and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with Client and on an ongoing basis. The Client identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.
During the account registration process an individual Client provides the following identification information to the Company:
During the account registration process a corporate Client provides the following identification information to the Company as a minimum:
Appropriate documents for verifying the identity of Client include, but are not limited to, the following:
The information and documents will be automatically verified by the Company’s electronic system or 3rd party identity verification software or by the Company’s staff. The Client’s information is verified against electronic databases for confirmation of identity details and legal status such as criminal record, political associations, sanctions list etc.
The 3rd party system that is used by the company for verification purposes fulfils the below conditions:
Potential sanctions matches are reviewed by the responsible persons and if the matches are found to be accurate and true the Client gets rejected.
When making a funds deposit or funds withdrawal via credit/debit card which is not 3D Secure, a Client is required to provide a scanned copy or photo of the credit/debit card (front and back side). The front side of credit/debit card should show the cardholder’s full name, the expiry date and the first six and the last four digits of the card number (the rest of the digits may be covered). The copy or scan of the reverse side of credit/debit card should show the cardholder’s signature, but the CVC2/CVV2 code must be masked.
If an existing Client either refuses to provide the information described above or if a Client has intentionally provided misleading information, the Company, after considering the risks involved, will consider closing any of the existing Client’s accounts.
The Regulations measures require further research and identification of Clients who may pose a potentially high risk of money laundering/terrorism financing. If the Company has assessed that the business relationship with a Client poses a high risk, it will apply the following additional measures:
When obtaining information to verify the Client’s statements about source of funds or wealth, the Company’s staff will most often ask for and scrutinize details of the person’s employment status or business/occupation. The Company’s staff will ask for whatever additional data or proof of that employment/occupation that may be deemed necessary in the situation, particularly the appropriate confirming documents (employment agreements, bank statements, letter from employer or business, financial statements etc.).
The Company will conduct ongoing Client due diligence and account monitoring for all business relationships with Clients. It particularly involves regularly reviewing and refreshing Company’s view of what its Clients are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Client. It can also include anything that appears to be a material change in the nature or purpose of the Client’s business relationship with Company.
Refund Policy
Effective Client Due Diligence (”CDD”) measures are essential to the management of money laundering and terrorist financing risk. CDD means identifying the Client and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with Client and on an ongoing basis. The Client identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.
During the account registration process an individual Client provides the following identification information to the Company:
During the account registration process a corporate Client provides the following identification information to the Company as a minimum:
Appropriate documents for verifying the identity of Client include, but are not limited to, the following:
The information and documents will be automatically verified by the Company’s electronic system or 3rd party identity verification software or by the Company’s staff. The Client’s information is verified against electronic databases for confirmation of identity details and legal status such as criminal record, political associations, sanctions lists etc.
The 3rd party system that is used by the company for verification purposes fulfils the below conditions:
Potential sanctions matches are reviewed by the responsible persons and if the matches are found to be accurate and true the Client gets rejected.
When making a funds deposit or funds withdrawal via credit/debit card which is not 3D Secure, a Client is required to provide a scanned copy or photo of the credit/debit card (front and back side). The front side of credit/debit card should show the cardholder’s full name, the expiry date and the first six and the last four digits of the card number (the rest of the digits may be covered). The copy or scan of the reverse side of credit/debit card should show the cardholder’s signature, but the CVC2/CVV2 code must be masked.
If an existing Client either refuses to provide the information described above or if a Client has intentionally provided misleading information, the Company, after considering the risks involved, will consider closing any of the existing Client’s accounts.
The Regulations measures require further research and identification of Clients who may pose a potentially high risk of money laundering/terrorism financing. If the Company has assessed that the business relationship with a Client poses a high risk, it will apply the following additional measures:
When obtaining information to verify the Client’s statements about source of funds or wealth, the Company’s staff will most often ask for and scrutinize details of the person’s employment status or business/occupation. The Company’s staff will ask for whatever additional data or proof of that employment/occupation that may be deemed necessary in the situation, particularly the appropriate confirming documents (employment agreements, bank statements, letter from employer or business, financial statements etc.).
The Company will conduct ongoing Client due diligence and account monitoring for all business relationships with Clients. It particularly involves regularly reviewing and refreshing Company’s view of what its Clients are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Client. It can also include anything that appears to be a material change in the nature or purpose of the Client’s business relationship with Company.
The Company’s Refund Policy is an integral part of the Client Agreement and can be found on the Company’s website at www.finsaitrade.com The Refund Policy contains all the relevant information regarding payments to and from the Company and measures taken prevent money laundering and terrorist financing.
Personnel
AML Compliance Officer
The Company shall appoint an AML Compliance Officer, who will be fully responsible for the Company’s AML and CFT program and report to the Board of the Company or a committee thereof any material breaches of the internal AML policy and procedures and of the Regulations, codes and standards of good practice.
Employees
The Company shall appoint an AML Compliance Officer, who will be fully responsible for the Company’s AML and CFT program and report to the Board of the Company or a committee thereof any material breaches of the internal AML policy and procedures and of the Regulations, codes and standards of good practice.
All Company employees, managers and directors must be aware of this policy. Employees, managers and directors who are engaged in AML related duties must be suitably vetted. This includes a criminal check done at the time of employment and monitoring during employment. Any violation of this policy or an AML program must be reported in confidence to the AML Compliance Officer, unless the violation implicates the AML Compliance Officer, in which case the employee must report the violation to the Board of Directors.
Employees who work in areas that are susceptible to money laundering or financing terrorism schemes must be trained in how to comply with this policy or the AML program. This includes knowing how to be alert to money laundering and terrorism financing risks and what to do once the risks are identified.
Employee Training Program
The Company provides AML training to employees who will be dealing with Clients or will be involved in any AML checking, verification or monitoring processes. The Company may conduct its training internally or hire external third-party consultants.
Each person employed within the Company is assigned a supervisor who teaches him or her in relation to all policies, procedures, Client documentation forms and requirements, forex markets, trading platforms, etc.
The Company’s AML training program is aimed to ensure its employees receive appropriate training level with regards to any possible AML/TF risks.
Content of training
The Company’s AML and risk awareness training includes the following content: