*** What is an AML policy:
Anti-money laundering policy is a combination of measures used by a financial institution to stop the reintroduction of the proceeds of illegal activities. The implementation of such rules is mandatory and overseen by regulatory authorities.
*** General :
Money Laundering has been identified as a major threat both to ETIHAD WALLET LTD and to the banking community generally. ETIHAD WALLET LTD is officially registered in United Kingdom by name of ETIHAD WALLET LTD and registry number 13100446.
*** Proccessing of ETIHAD WALLET LTD :
ETIHAD WALLET LTD has issued an anti-money laundering manual.
The appointment of a Money Laundering Reporting Officer.
Procedures regarding the identification of customers including the prohibition of numbered accounts or accounts for shell banks.
Regular internal and external inspection and auditing of compliance with procedures.
Procedures for reporting suspicious transactions.
Procedures for profiling customer's transactions and business.
Procedures for education and training of employees in anti-money laundering requirements.
Implementing internal controls for the prevention of money laundering.
*** Know your Customer (KYC) Guidelines
ETIHAD WALLET LTD has strict KYC procedures in place which include the validation of business and individual customer identities and place of residence prior to commencing business with any customer. Such information is updated on a regular basis and archived once the business relationship finishes. The procedures include profiling of the customer's transactions as to size, frequency, nature and hence potential risk. No anonymous or numbered accounts are opened nor does ETIHAD WALLET LTD open any accounts for banks which do not maintain a physical presence in their country of incorporation i.e. shell banks.
*** Terrorist Financing
All accounts are screened on a regular basis against lists of suspected or designated criminals and terrorists provided by the regulator and any matches therewith reported to the regulators.
*** Unusual Large Transactions
All cash transactions larger than $10,000 must be reviewed, reported and the rationale thereof clarified before proceeding with the transaction.
It is a requirement that all employees who have potential contact with customers or who process transactions on behalf of customers are required to undertake anti-money laundering training. Relevant new employees should be provided with an AML ‘Joining Pack’ summarizing relevant regulations and their responsibilities with regard to them. They must also be given AML/CFT training within three months of joining.
*** Record Retention
All ETIHAD WALLET LTD units are required by law to maintain records which are appropriate to the scale, nature and complexity of the customer's business. All identity or business relationship records must be kept for a minimum period of 5 years from the end of the bank's relationship with the customer.
*** Compliance and audit
ETIHAD WALLET LTD’s internal audit and compliance functions (The Unit MLRO) have important responsibilities in independently evaluating and ensuring adherence to local and Group policies.
ETIHAD WALLET LTD's internal audit unit conduct periodic review to ensure compliance with the AML procedures.