AML Policy

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AML Policy

  • Sanctions:

    Sanctions are described as measures enforced by governments or international organizations against certain people, groups, or nations. Restrictions on trade, money transfers, travel, and other activities are examples of sanctions.
    Direct Remit will abide by the following list of Sanctions
    * The Uk autonomous sanctions regime
    * The United Nations Security Council sanctions
    * The European Union sanctions
    * The United States sanctions
    * The Swiss sanctions
    * The Canadian sanctions

    Direct Remit will abide with all sanctions-related laws and rules by:
    * The Sanctions and Anti-Money Laundering Act 2018 (SAMLA)
    * Checking the compliance with sanctions of all customers and transactions
    * Putting in place the right controls to stop sanctions violations
    * Training employees on sanctions compliance

    Procedure for determining and controlling sanctions risks:
    Direct Remit Ltd will recognize and control sanctions risks by:
    * Performing regular risk analyses
    * Putting in place the right controls to reduce risks
    * Observing potential changes in the landscape of sanctions.
  • AML / AFT Policy

    Direct Remit Ltd is dedicated to abiding by all applicable rules and legislation pertaining to countering money laundering and terrorist financing. In addition to adhering to national and international laws and standards, we are dedicated to the following local AML/AFT rules and regulations
    * Proceeds of Crime Act (POCA) Introduced in 2002 (Amended 2007)
    * The Terrorism Act of 2000 (Amended 2007)
    * UK AML Regulations 2017
    * Money Laundering Regulations 2019
    * Sanctions and Anti Money Laundering Act (SAMLA) 2018

    International laws, Best practices and industry standards, including:
    * HM Treasury – United Kingdom
    * Financial Action Task Force (FATF) Recommendations
    * Bank Secrecy Act
    * USA Patriot Act
    * Office of Foreign Assets Control (OFAC) of the US Department of the Treasury
    * United Nations Security Council (UNSC)
  • Declaration

    Direct Remit Ltd is devoted to conducting business honestly, legally and securely, and in accordance with all applicable laws. To identify, prevent, and disclose any risks related to money laundering and terrorist financing, Direct Remit Ltd has put in place thorough AML & ATF policies and procedures, effective Sanction screening, and an AML Monitoring system.

    The company also employed Compliance Risk Management Solutions, such as "World-Check," the most comprehensive database for politically exposed persons (PEP) and sanctions, a single source lookup tool, such as "Word-Check Online," and research tools for conducting due diligence and additional investigations.

    Consequences of Noncompliance with UK CFT / AML Regulations
    Direct Remit Ltd is fully aware of Noncompliance with the UK’s CFT / AML regulations may result in financial penalties or up to 14 years imprisonment depending on the nature and severity of the offense. The FCA has the authority to wind up or restrict the operations of firms that are found guilty of wrongdoing and may also recover funds and assets that are involved in money laundering offenses via court or civil proceedings. AML compliance breaches in the UK may also result in significant reputational damage for the firms involved.
  • Record Retention

    Record-Keeping ensures that the company is able to provide basic information about its customers at the request of relevant authorities. Direct Remit Ltd shall immediately make available any or all of its books and records upon request by HMRC or any other regulatory agencies.

    "All the records / documents of transfers should be kept for a minimum period of 5 years from the date of transaction.

    Direct Remit Ltd shall at all times maintain the confidentiality of information indicated in the transaction records
  • Risk Based Approach

    In order to understand the ML/TF risks each customer poses, a customer risk assessment should consider a number of factors. These include the verification of identity, considering how to engage with them –the product and service they access, the type of transaction they carry out and how often, the geographic location to which the customer is linked.

    Dynamic Customer Risk Assessment framework at Direct Remit Ltd

    Customer risk is assessed at three different levels (Continuous Monitoring)
    1 At the time of Onboarding /Registration (RBA – Customer Identification factors)
    2 Customer Profiling (RBA – Continuous profile maintenance)
    3 At transaction level (RBA – Whenever customer transact)

    Overall Risk is the average of aforementioned three levels of risk which are
    * 30% of onboarding risk factors/Registration
    * 50% of transaction risk factors
    * 20% of customer membership/Profile risk factors

    After registration/onboarding process each customer is assigned with risk rating based on the predefined risk range.