AML & KYC Policy
As part of this commitment QTM will adopt strict compliance of all applicable AML rules and regulations with specific emphasis on POCA and the MLR. QTM is aware that MSB have in the past been targets of organized crime seeking to launder the proceeds of illicit activity. QTM will always seek to disrupt this activity by cooperating fully with the authorities and reporting all suspicious activity to NCA.
All staff must take steps to ensure compliance with this policy and ensure that they fully understand the material contained in this manual.
It is the policy of QTM that staff must receive AML training on commencement of their duties. Staff will be given a copy of this manual and will be tested on its contents before starting any client facing duties. The MLRO holds copies of all training materials. The updated AML training is given annually to all staff. Records of all training including dates delivered and by whom are kept on staff personnel files.
All issues relating to SAR must be referred to MLRO in the first instance. A copy of this manual will be provided to all employees on commencement of their work for the company. Responsible for overall compliance policy of QTM and ensuring adequate resources are provided for the proper training of staff and the implementing of risk systems. This includes computer software to assist in oversight
Followings are policy & procedures of the QTM to establish and maintain appropriate and risk sensitive money service.
Customer due diligence
Risk assessment and management
The monitoring and management of compliance, and
The internal communication of such policies and procedures,
In order to prevent activities related to money laundering and terrorist financing. These policies and procedures shell identify and scrutinize:
Complex or unusually large transactions.
Unusual patterns of transactions which have no apparent economic or visible lawful Purpose.
Any other activity which could be considered to be related to money laundering or Terrorist financing
Specify the additional measures that will be taken to prevent the use of products and Transactions that favour anonymity for money laundering or terrorist financing.
Determine whether a customer is a politically exposed person.
Nominate an individual in the organization to receive disclosures under the law.
Ensure employees report suspicious activity to the Nominated Officer.
Ensure the Nominated Officer considers such internal reports in the light of available information and determines whether they give rise to knowledge or suspicion or reasonable grounds for knowledge or suspicion of money laundering or terrorist financing.
Customer Due Diligence
QTM has the following policy & procedures concerning Due Diligence All Customers will be asked before a transaction is carried out for evidence of their identity (including verification as to politically exposed person status). The identity that is required will depend on certain factors such as the status of the customer (for example they may represent a business) and the type of transaction they wish to carry out (the transaction may vary from a small amount to a considerable amount and may include cash). Each factor will carry a certain degree of risk, and it is the identification of these risks and the management of these risks that provide good Anti Money Laundering regulatory control.
High Risk Situations
Enhanced due diligence must be applied in situations which by their nature can present a higher risk of money laundering or terrorist financing (i.e. Risk indicators mentioned in MLR). Business’s risk assessment and management systems must be capable of identifying such situations and appropriate enhanced due diligence measures must be applied to mitigate the risk involved. For example, enhance due diligence measures could include:
Obtaining details of the source of the customer’s funds and the purpose of the transactions.
applying supplementary measures to verify or certify the documents supplied or requiring certification by a credit or financial institution.
Ensuring that the first payment of the operations is carried out through an account opened in the customer’s name with a credit institution.
In addition, the treasury may, from time to time, issue advice about high risk situations to the regulated sector. Such advice may include advice about dealing with customers in or receiving funds from countries that present a high risk of money laundering or terrorist financing. Advisory notices have been issued about Iran, Nauru and Antigua & Barbuda following concerns expressed by the financial action task force.
Know Your Customer Policy
The first requirement of knowing your customer for money laundering purpose is to be satisfied that a prospective customer is who he/she claims to be. All employees at QTM and all Independent Contractors, who assist customers in processing transactions, are required to obtain as much information as possible from customers, especially regular customers in order to identify them and verify their identities. Engage regular customers in general conversation. It is much easier to ask customers about matters, such as the source of funds used to conduct large transactions, once you have developed a good rapport with them. If a customer becomes nervous or cannot provide a reasonable explanation for his repeated transactions, request identification if you have not already done so, submit a suspicious activity report (SAR) to your MLRO and refrain from conducting any more transactions for the customer. In these circumstances you should make contemporaneous notes of any suspicious conversations with customers and if a regular customer place these notes on their file.