AML POLICY

The Financial services industry and the structure of modern economy faces serious challenges in preventing money laundering, such as making the possession, use or disposal of money obtained from criminal activities appear to be legal, and terrorism financing or rendering financial services with the knowledge that money is intended to finance terrorist acts or criminal organizations.

Organisations or individuals who's income is earned illegally make various attempts to legalize their income. For example, criminals may use other people's personal data, including data obtained illegally. This can become a major problem for people who become victims of fraud and are uninvolved in criminal activities.

AML Laws: To stop or reduce the impact of money laundering, organisations worldwide performing operations with money or property are obliged to comply with anti-money laundering laws, verify client identity, and assist government agencies and financial organizations working to fight money laundering. Citizen BMC does everything it can to ensure compliance with anti-money laundering regulations and terrorism financing.

AML Policy

Citizen BMC KYC Procedure

Citizen BMC performs vigorous checks on client registration as part of complying with client identification procedures. Our specialist support team conducts various non-trading checks to monitor compliance. We may request personal data or take actions to verify client information. Verification may take up to 3 working days but is usually completed within an hour.

Compliance with the Privacy Agreement

Client identification ensures compliance with AML regulations and terrorism financing laws. Personal data is handled in accordance with privacy provisions. This process aims to protect you from fraud and is not based on suspicion.

Monitoring and Reporting

Transaction monitoring occurs within appropriate business units, particularly transactions $5,000 or more or those flagged suspicious. All reports will be documented.

Suspicious Activity

Suspicious activities ("red flags") require additional due diligence. Without reasonable explanation, they will be reported to the AML Compliance Committee. Examples include:

  • The customer exhibits unusual concern about compliance or refuses to provide relevant information.
  • The customer engages in transactions lacking business sense or inconsistent with their strategy.
  • The customer provides false or misleading information on fund sources.
  • Other red flags include multiple accounts, frequent large cash deposits, unexplained extensive activity, and transactions without business purpose.

Knowing your customer is key to recognizing suspicious activity by understanding their legitimate business activities. Questions to consider include transaction size consistency, rationale, and changes in transaction patterns.

Suspicious Scenarios

Causes for suspicion include clients reluctant to provide proof of identity, reliance on introducers, unclear source of investment funds, irrational transactions, and international transaction concerns.

  • Reluctance to provide personal or financial information.
  • Changing transaction methods without explanation.
  • Clients unwilling to provide normal information for no rational reason.
  • Persuasive arguments by potential money launderers should be critically evaluated.

Reporting a Suspicion

Suspected transactions involving criminal proceeds must be reported promptly and in writing, regardless of whether business was written. Internal reports follow regardless of the transaction status.

Investigation

Upon AML Compliance Committee notification, an investigation begins to determine if a Suspicious Activity Report (SAR) should be filed. The investigation includes reviewing all relevant information. Results are confidential except to those with a legitimate need to know and never disclosed to the subject or their associates.

Freezing of Accounts

Accounts linked to criminal activity or fraudulent instructions must be frozen. If the account holder is suspected of involvement, freezing may be required.

Enquiries

For further AML enquiries, please contact us at [email protected]