AML KYC Policy

1. Introduction

This AML KYC (Anti-Money Laundering and Know Your Customer) policy applies to all MorfinFx officers, employees, appointed producers, and the products and services offered by MorfinFx. We are committed to combating money laundering and maintaining strict KYC procedures.

2. Responsibility and Cooperation

All business units and locations within MorfinFx are committed to a collective effort against money laundering. Cooperation and adherence to this policy are expected from all staff members.

3. Risk-Based Procedures

Each business unit and location within MorfinFx has implemented risk-based procedures designed to prevent, detect, and report suspicious transactions. These procedures aim to ensure compliance with AML regulations and safeguard the integrity of our financial system.

4. Documentation and Record Keeping

Efforts made to prevent money laundering, including transaction records, reports, and related documents, will be well-documented and retained. Comprehensive record-keeping is vital for regulatory compliance and internal auditing.

Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

5. AML Compliance Committee

MorfinFx has established an AML Compliance Committee responsible for overseeing the implementation of this policy. The committee is authorized to initiate Suspicious Activity Reports (SARs) or any other required reporting to relevant law enforcement or regulatory agencies when suspicious activities are identified.

6. Reporting and Contact with Authorities

In case of contact by law enforcement or regulatory agencies concerning this AML KYC Policy, all communication shall be directed to the AML Compliance Committee. We will fully cooperate with these agencies to support investigations and prevent money laundering activities.

7. Policy Review and Updates

This policy will undergo periodic reviews to ensure its effectiveness and compliance with changing regulations. Necessary updates will be made to address new challenges and maintain a robust AML KYC framework.

8. Money Laundering and Terrorist Financing

This section defines money laundering and provides an understanding of the processes involved, including placement, layering, and integration. It also discusses the concept of Counter-Terrorist Financing (CTF) and its risks.

9. Risk-Based Approach

To conduct due diligence regarding AML procedures, MorfinFx takes a risk-based approach. This involves allocating resources in proportion to the level of risk associated with a particular relationship, product, or country.

10. Customer Identification Program

MorfinFx has implemented a Customer Identification Program (CIP) to collect and verify customer identification information. Notice to customers regarding the requirement for identification information will be provided, and such information will be recorded.

11. Monitoring and Reporting

This section outlines the transaction-based monitoring process, detailing what transactions are monitored and reported. It mentions the identification of suspicious activity and reporting to the AML Compliance Committee.

12. Suspicious Activity and Red Flags

Recognizing suspicious activities and red flags is crucial in preventing money laundering. This section lists examples of red flags and explains what steps should be taken when red flags are detected.

Reporting a Suspicion

This section details the reporting process when there's suspicion of money laundering or fraudulent activity, emphasizing the need for immediate written reporting.

14. Investigation

Upon receiving a report, the AML Compliance Committee will initiate an investigation. The scope of the investigation, including data sources and methods, is discussed here.

15. Freezing of Accounts

When funds are believed to be linked to criminal activity or fraudulent instructions, this section outlines the process for freezing accounts, ensuring compliance with regulatory requirements.