Anti Money Laundering

01Legal framework

The laws and standards this policy follows include:

• Money Laundering (Prevention) Act, Cap. 12.20
• Proceeds of Crime Act, Cap. 3.04
• Anti-Terrorism Act, Cap. 3.16
• Money Services Business Act, Cap. 12.22
• United Nations sanctions and counter-proliferation financing legislation
• Guidance and requirements issued by the Financial Intelligence Authority (FIA) of Saint Lucia, the Financial Action Task Force (FATF) and the Caribbean Financial Action Task Force (CFATF)

02How money laundering works

Money laundering usually passes through three stages, and our controls are built to catch each of them:

Placement

Criminal proceeds are first brought into the financial system, for example by depositing them.

Layering

The funds are moved through complex transfers, nominees or shell companies to hide where they came from.

Integration

The funds return to the economy looking like legitimate money or business assets.

Two offences apply directly to everyone working for the Company:

Tipping off

Telling a person that a suspicious activity report has been made, or that an investigation has started, is a criminal offence.

Failure to disclose

Not reporting a suspicious transaction within 7 days is an offence under the law.

03Know your customer

Before an account can trade or withdraw, we verify who the client is. Records of identity and transactions are kept for at least 7 years from the date of the transaction or the end of the business relationship.

Individual clients

Proof of identity: a valid passport, national ID card or driving licence. Proof of address: a utility bill (gas, water or electricity) or a bank statement issued within the last 3 months.

Corporate clients

Certificate of incorporation, articles of association and business licence; proof of the company’s address in its own name; proof of identity for directors, authorised signatories and every shareholder owning 25% or more; and verification of the ultimate beneficial owner (UBO).

04Due diligence

Customer due diligence

Carried out when a business relationship begins, for any one-off transaction above $25,000, and whenever activity looks suspicious. Anonymous accounts are not permitted.

Enhanced due diligence

Applied to higher-risk clients, including politically exposed persons (PEPs), accounts opened without meeting in person, trusts, companies with bearer shares and cross-border relationships. It includes checking the source of wealth, and needs senior management approval.

Clients who need enhanced due diligence may also be asked for a source of funds declaration and proof of income.

05Ongoing monitoring

Our AML Compliance Officer monitors account activity continuously through automated systems, comparing each account’s turnover against the client’s declared profile.

Any transaction or activity above $25,000 requires a signed Source of Funds Declaration. Making a false declaration is a serious offence.

06Suspicious activity reports

Where there are reasonable grounds to suspect money laundering or terrorist financing, the AML Compliance Officer files a suspicious activity report (SAR) with the Financial Intelligence Authority of Saint Lucia. We may also freeze funds, refuse transactions or close accounts where the law requires it.

07Review of this policy

This policy is audited once a year and reviewed by senior management at least every six months, so that it keeps pace with the law and with new risks.