AML/KYC
1. THE AML POLICY’S OBJECTIVE
Gift Card Collective (“We”, “our”) is required to comply with anti-money laundering (AML) regulations in our operations. To reduce the risk of our services being used to facilitate financial crimes, all of our employees are committed to pursuing the highest standards of AML and Know Your Customer (KYC) compliance.
We have implemented the AML Policy framework to ensure that all necessary steps are taken to ensure the full safety of our services. We are committed to following the provisions specified in the USA AML laws, as well as the USA and international AML guidelines, in this AML Policy.
2. WHAT EXACTLY IS AML POLICY?
The AML Policy is the procedure in place to prevent our services from being used for money laundering, terrorist financing, or any other illegal activity. KYC measures are included in the AML Policy. The goal of KYC measures is to help businesses better know and understand their customers while also assisting them in risk management. In the future, we may revise this procedure to ensure compliance with existing laws and best AML practices.
In the event of potentially suspicious or unusual transactions or customer behavior, we take appropriate steps to address the risks. As deemed appropriate, all staff handling transactions may request additional documents such as proof of fund source, etc.
We maintain all records, including customer identification documents and related data, in a well-organized manner. All customer and transactional data is kept confidential and in accordance with personal data protection laws.
Our AML Policy includes the following provisions:
•- Before entering into a financial business relationship, the customer must be identified and verified.
•- Establishment and maintenance of risk-based customer due diligence, including enhanced due diligence for higher-risk customers.
•- Transactional monitoring of customer financial behavior based on risk assessment.
•- Internal and external procedures for reporting suspicious activity to law enforcement authorities.
•- Ongoing AML training for our staff.
If we discover any suspicious activity, false documents, or non-cooperation by the customer during the customer’s due diligence process, we are required to reject the customer’s documents, close the account, and terminate the business relationship.
AML Policy
1. Risk assessment encompassing all aspects of business activity.
Gift Card Collective will monitor its clients’ financial activities with a high risk-based approach.
This will be done while preparing the accounts, filing tax returns, or doing any other business with the client.
The company will actively refuse high-risk clients who are identified as the following:
• Clients with businesses that deal with large sums of money or unusually large transactions.
• Clients with larger one-time transactions or multiple transactions completed by the same customer in a short period of time.
• Clients with complicated business ownership structures that may conceal underlying beneficiaries.
• Clients based in, or conducting business in, a high-risk jurisdiction, or a jurisdiction with a history of corruption, organized crime, and drug production/distribution.
• Cases in which the source of funds cannot be easily established.
• Unusual patterns of transactions with no discernible economic or legal purpose.
• Money sent or received from areas where there is a high level of criminality or terrorist activity. The company will monitor its business relationships with customers on an ongoing basis to ensure that the documents provided and the date or information held proving the customer’s identity are kept up to date.
The following are some examples of suspicious or high-risk changes in a client’s situation:
• A sudden increase in business from an existing customer; • Unusual transactions that are inconsistent with the customer’s known activities; • Peaks of activity at specific locations or times; • Unfamiliar or unusual types of customer or transaction.
When there is reason to suspect a transaction, the client will be asked to identify and verify the source or destination of the transaction, whether they are individuals or corporate beneficial owners.
If there is no reason to suspect, no action is required.
2. Policy and Procedures.
Policy, rules, and guidance for all aspects of a business’s operations, including KYC/AML policy.
This is Gift Card Collective’s Anti-Money Laundering (AML) Policy and Procedures, which are in accordance with the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations. GCC is referred to as “Gift Card Collective,” “we,” “us,” or “our” in this AML Policy. GCC is a data controller under this AML Policy, which outlines how the company may use your Personal Data as a data controller. The company will actively prevent and take precautions to avoid being used as a conduit for money laundering, terrorism financing, or any other activity that facilitates money laundering or the funding of terrorist or criminal activities.
To that end,
• All new and existing clients’ identities will be verified to a reasonable degree of certainty.
• Client Buying & Selling Crypto Currency transactions will be monitored using a risk-based approach.
• Suspicious activity will be reported, and all AML activities will be documented.
• Stephen Manuel will serve as the Money Laundering Reporting Officer (MLRO), coordinating the company’s AML policies and procedures. • Before meeting or contacting clients or potential clients, all staff members are required to acknowledge that the policy and procedures have been read and understood.
3. Due diligence.
Procedures for due diligence.
The company has implemented a Know-Your-Customer (KYC) and Know-Your-Business (KYB) policy to ensure that all new and existing clients’ identities are verified to a reasonable level of certainty. All individual clients, all directors and shareholders with a 25% or greater stake in client companies, all partners in client partnerships, and every board member of client charities will be included.
Proof of identity with first and last name, date of birth, issue and expiry dates, and document number.
Documents that are acceptable:
• A valid passport
• A valid driver’s license (front and back)
• A valid government-issued identification card
Electoral identification cards are not accepted.
Proof of Address displaying first and last name, address, and date
Documents that are acceptable:
• A bank, credit card, or mortgage statement from the last three calendar months (either hard copy or electronic PDF statements are acceptable)
The buyer and his or her partner’s names may appear on the statement.
• Utility (water, gas, or electricity), telephone landline, broadband, or television license bill from the previous three calendar months (either hard copy or electronic PDF statements are acceptable)
• A council tax bill dated within the last six months (either hard copy or electronic PDF statements are acceptable)
Verification of a Bank Account
Documents that are acceptable:
• In the case of a personal bank account
I. A bank statement that includes your name, account number, and sort code (either hard copy or electronic PDF statements are acceptable)
• In the case of a Limited/LTD Business Bank Account
I. Verifiable company name and number from the company house
II. Listed as a director or owner with the company house
III. A bank statement that includes your name, account number, and sort code (either hard copy or electronic PDF statements are acceptable)
• A Business Bank Account for a Sole Trader
I. A business bank statement dated within the last three calendar months that shows the business name under which they are “trading” (either hard copy or electronic PDF statements are acceptable)
4. Transaction tracking.
The MLRO will regularly monitor the following procedures to ensure they are carried out in accordance with the company’s AML policies and procedures:
• Verifying the identity of the client; reporting suspicious transactions; and maintaining records. The MLRO will also keep an eye on any developments with the MLR as well as the MLR supervisory body’s requirements.
When necessary, changes will be made to the company’s AML policies and procedures to ensure compliance.
As soon as knowledge or suspicion that criminal proceeds exist, a Suspicious Activity Report (SAR) will be filed with FINCEN.
The MLRO will be in charge of determining whether the suspicion of illegal activity is strong enough to warrant the submission of a SAR.
5. Education.
Staff training is unnecessary because the company only has one employee involved in ML compliance, who is also the MLRO. All affected employees have received training on their responsibilities under money laundering legislation, as well as how to identify and handle transactions that may involve money laundering.
Stephen Manuel is the GCC representative who will serve as the Money Laundering Reporting Officer.
Steve@giftcardcollective.net
+1-907-952-5307