Anti-Money Laundering (AML) Policy
1. Introduction
OGWASON INVESTMENTS (SMC) LTD (“we,” “our,” “us”) is committed to the highest standards of anti-money laundering (AML) compliance. This AML Policy outlines our procedures for preventing, detecting, and reporting money laundering and terrorist financing activities.
2. Purpose
The purpose of this AML Policy is to ensure that we comply with all applicable laws and regulations regarding money laundering and terrorist financing. It is designed to protect the company from being used to facilitate financial crime.
3. Scope
This policy applies to all employees, directors, officers, and agents of OGWASON INVESTMENTS (SMC) LTD. It covers all transactions and activities conducted through our services.
4. Money Laundering Defined
Money laundering involves disguising the origins of illegally obtained money so that it appears to come from legitimate sources. This typically includes three stages:
- Placement: Introducing illicit funds into the financial system.
- Layering: Concealing the source of the funds through complex transactions.
- Integration: Reintroducing the laundered money into the economy as legitimate funds.
5. Key Principles
5.1 Know Your Customer (KYC):
We implement rigorous KYC procedures to verify the identity of our clients and understand the nature of their activities. This includes:
– Collecting and verifying identification information (e.g., name, address, date of birth, identification documents).
– Understanding the purpose and intended nature of the business relationship.
– Conducting ongoing monitoring of transactions and activities.
5.2 Risk-Based Approach:
We adopt a risk-based approach to AML compliance, assessing the risks associated with different clients, transactions, and services. Enhanced due diligence is applied to high-risk clients and transactions.
5.3 Record Keeping:
We maintain comprehensive records of all transactions and client information for at least five years. This includes documentation related to KYC, transaction details, and any reports of suspicious activities.
5.4 Suspicious Activity Reporting:
We are committed to identifying and reporting suspicious activities that may be indicative of money laundering or terrorist financing. Employees are required to report any suspicious activity to the designated AML Compliance Officer.
6. Roles and Responsibilities
6.1 AML Compliance Officer:
The AML Compliance Officer is responsible for overseeing the implementation of this policy, including:
– Ensuring compliance with relevant laws and regulations.
– Providing training and guidance to employees.
– Monitoring transactions and activities for suspicious behavior.
– Reporting suspicious activities to the appropriate authorities.
6.2 Employees:
All employees are responsible for:
– Complying with this AML Policy and related procedures.
– Completing mandatory AML training.
– Reporting any suspicious activities to the AML Compliance Officer.
7. Training and Awareness
We provide regular AML training to all employees to ensure they understand their responsibilities and can identify potential money laundering activities. Training covers:
– The principles of AML and terrorist financing.
– How to identify and report suspicious activities.
– The importance of KYC and record-keeping.
8. Monitoring and Auditing
We regularly monitor and audit our AML program to ensure its effectiveness and compliance with legal requirements. This includes:
– Periodic reviews of KYC procedures and records.
– Transaction monitoring to identify unusual or suspicious patterns.
– Internal audits of AML compliance activities.
9. Reporting and Escalation
Employees must report any suspicious activities or transactions immediately to the AML Compliance Officer. The AML Compliance Officer will investigate and, if necessary, report the findings to the relevant authorities.
10. Consequences of Non-Compliance
Non-compliance with this AML Policy can result in severe consequences for the company and individuals, including legal penalties, reputational damage, and disciplinary actions. Employees found to be in violation of this policy may face disciplinary measures, up to and including termination of employment.
11. Review and Updates
This AML Policy will be reviewed and updated regularly to ensure it remains effective and compliant with current laws and regulations. Any changes will be communicated to all employees.
12. Contact Information
For any questions or concerns regarding this AML Policy, please contact the AML Compliance Officer at:
OGWASON INVESTMENTS (SMC) LTD
Company Address: Kampala – Uganda
Email Address: info@ogwasoninvestments.com
Phone Number: +256777714572