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ANTI-MONEY LAUNDERING/ KYC POLICIES, CONTROLS AND PROCEDURES

DOCUMENT UPDATED THE 3 TH DECEMBER 2019

, as a member of the AC Group, will also act in accordance with this Policy Rule as laid down in this Group Policy AML/KYC statement.
It is the policy of AC Group that all members of staff at all levels shall actively participate in preventing the services of AC Group from being exploited by criminals and terrorists for money laundering purposes. This participation has as its objectives:

  • ensuring AC Group’s compliance with all applicable laws, statutory instruments of regulation, and requirements of AC Group’s supervisory authority
  • protecting AC Group and all its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements
  • preserving the good name of AC Group against the risk of reputation damage presented by implication in money laundering and terrorist financing activities
  • making a positive contribution to the fight against crime and terrorism.

To achieve these objectives, it is the policy of AC Group that:

  • every member of staff shall meet their personal obligations as appropriate to their role and position in AC Group
  • neither commercial considerations nor a sense of loyalty to Platform Users shall be permitted to take precedence over AC Group’s anti-money laundering commitment
  • AC Group shall appoint the sole practitioner to be responsible for anti-money laundering compliance (the responsible AC Officer). AC Group shall notify the supervisory authority (if applicable) and supply the name of the responsible director
  • AC Group shall appoint a Money Laundering Reporting Officer (MLRO). AC Group shall appoint a deputy to cover in the absence of the MLRO. The MLRO and deputy shall be afforded every assistance and cooperation by all members of staff in carrying out the duties of their appointments
  • AC Group shall carry out a business-wide assessment of the risks of money laundering and terrorist financing to which AC Group is subject and design and implement appropriate controls to mitigate and manage effectively the risks identified
  • AC Group shall establish and maintain documented, proportionate policies and procedures, including controls, which outline the positive actions to be taken by staff to prevent money laundering and terrorist financing in the course of their work. The MLRO shall keep these under review to ensure their continuing appropriateness.

POLICY AND PROCEDURE FOR THE ASSESSMENT OF MONEY LAUNDERING RISK

POLICY

It is the policy of AC Group to identify and assess the money laundering and terrorist financing risks represented by the business we conduct so that we can mitigate that risk by applying appropriate levels of persons and companies using the platform as exploited by (the Platform Users). The Platform Users are the so-called Service Providers that is the Studio and the Performer with which/whom has concluded the Studio Agreement respectively the Performer Agreement. Performer is also referred to as “Model”. These Service Providers offer and sell their services to their customers (Users) on the SNV Platform.

CONTROLS AND PROCEDURES

  1. AC Group shall assess the money laundering risk represented by the Platform Users and the business conducted according to three levels:
    • the range normally dealt with by AC Group, requiring AC Group’s normal level of client due diligence
    • an exceptionally high level of risk requiring an enhanced level of client due diligence
    • a negligible level of risk requiring only simplified due diligence.
  2. AC Group shall identify and maintain lists of risk factors (including those required by the Regulations) relating to the Platform Users, products or services, transactions, delivery channels and geographic areas of operation.
  3. AC Group shall assess the level of risk associated with these factors by analysing indicators including:
    • characteristics of the Platform User (individual or corporate, status, location, occupation)
    • the purpose of accounts or engagements, levels of assets and transactions
    • regularity or duration of business relationships.
  4. AC Group shall update the risk assessment annually to ensure new and emerging risks are addressed, and new information supplied by our supervisory authority is reflected.
  5. AC Group shall keep an up-to-date written record of all steps taken and shall provide the risk assessment and the information on which it was based.
  6. The money laundering or terrorist financing risk represented by each Platform User will be assessed:
    • during the new Platform User acceptance process (KYC), before any work is undertaken.
    • whenever AC Group’s process of ongoing monitoring indicates that a change in the business or operating environment of an established Platform User may represent a change in money laundering risk.
  7. The risk assessment in relation to a Platform User shall be carried out by the responsible AC officer who will determine appropriate due diligence measures in respect of each Platform User based on:
    • AC Group’s business-wide risk assessment
    • assessment of the level of risk arising in any particular case.
  8. A record must be made of the assessment of individual Platform User relationships, confirming that AC Group’s business-wide risk assessment has been taken into account, and any other relevant factors considered.

POLICY AND PROCEDURE FOR THE VERIFICATION OF IDENTITY OF THE PLATFORM USERS (KYC)

POLICY

It is the policy of AC Group to verify the identity of all Platform Users, ensuring that procedures reflect Platform User risk characteristics. When opening an account with the AC Group all Platform Users will be verified on the basis of the following procedures.

A. CONTROLS AND PROCEDURES FOR THE USE OF THE (SNV) PLATFORM

Platform Users who offer and sell their services on the SNV Platform – Performers and Studio’s – acting in the form of a corporate entity need to provide the following information:

  • Company Name
  • Official Registration number
  • Social form
  • Country of headquarters
  • Address of the headquarters
  • If applicable, intracommunity VAT number
  • Contact mail address
  • Phone number
  • All information about the beneficial owners.

The responsible AC Officer will check that such Platform User is appropriately incorporated (if applicable) and registered, and take the necessary steps to determine who are the principal beneficial owners, and the people with significant control, and their identity will be verified according to this procedure.

B. Platform Users who offer and sell their services on the SNV Platform – Performers and Studio’s – not acting in the form of a corporate entity need to provide the following information:

  • Name or identification of the non-individual Studio/Performer
  • Country of residence
  • Address
  • Phone number and contact mail address
  • A waver stating his obligations of any taxes due and statement that he can act as a non legal entity in his country (micro-entreprises).
Verification of identity
  1. The member of staff conducting verification of identity will complete the process by checking that the Studio/Performer is not the subject of sanctions or other statutory measures, using the screening methods set out by the MLRO. (Blacklist international terrorist, tel sms verification).
  2. For Studio/Performers, identity checks will be conducted by examination of:
    • one document containing a photograph confirming the Studio Manager/ Performer’s name, such as a valid passport
    • photo with the given identity document next to face
    • one document confirming the Studio Manager/Performer’s address, such as a utility bill (less than 3 months old and no mobile telephone bill). This document is required even if the document confirming name also has the address AC Group’s MLRO will maintain a list of acceptable documents or information obtained from a reliable source which is independent of the Studio/Performer:
    • only scanned coloured HR copy of the document, will be accepted for examination
    • sources of electronically held information must have been risk-assessed prior to use.
  3. In cases where a Platform User cannot produce acceptable documents, the responsible AC Officer will make a risk-based decision on accepting the documents that are available., consulting with the MLRO if appropriate.
  4. Where the Studio Manager/Performer is not a European resident, or will not be seen in person (that means via the webcam) by the member of staff carrying out the verification, the responsible AC Officer will make a risk-based decision on the means of verification to be accepted., consulting with the MLRO if appropriate.
Check of the beneficial ownership
  1. Where the Performer is not the beneficial owner of assets involved, the responsible AC Officer will take the necessary steps to determine who is the beneficial owner, and take reasonable measures to verify their identity, according to this procedure.
  2. The MLRO will prepare a format for use by the responsible AC Officer in requesting verification of identity and beneficial ownership information from the Studio/Performer and a procedure for following up when requests are not met within the statutory period.
  3. If all possible means of identifying the beneficial owner of a non-individual Studio/Performer have been exhausted without success, and recorded, the responsible AC Officer will seek the approval of the MLRO, to be given on a risk-sensitive basis, to treat as its beneficial owner the senior person responsible for managing the non-individual Studio/Performer.
  4. In respect of the ultimate beneficial owner(s) of the non-individual Studio’s/Performers the following information is required:
    • Title
    • Name and surname
    • Country of residence
    • Address
    • Date of birth
    • Country of birth
    • Id number
    • Reason why the individual is UBO (percentage of direct or indirect capital/ownership etc.)
  5. Where the Platform User is a listed company or a regulated firm, the responsible AC Officer will check that the Platform User is appropriately registered, and that the person with whom AC Group is dealing is properly authorised to act on the Platform Users behalf, and will verify the identity of that person according to this procedure, in addition to that of the non-individual Studio/Performer.
  6. In all cases assessed as presenting a higher money laundering risk, where enhanced Platform User due diligence is required, the responsible AC Officer will consult with the MLRO to decide on additional steps to verify the Platform User’s identity.
  7. All verification of identity processes as well as actions taken to verify the identity of non-individual Studio/Performer will be recorded. This will include keeping photocopies of all documents produced and email exchanges.
  8. For both the individual and the non-individual Studio’s/Performers, the responsible AC Officer will collect reference information of the bank account of such Studio/Performer:
    • Bic or IBAN
    • Name of the institution where the account is held
    • Address of said institution
  9. For both the individual Performers/Studio’s and the beneficial owners of the non-individual Performers/Studio’s, it will be monitored whether such person qualifies as a “politically exposed person”. When opening an account the following questions will be asked:
    • Are you a politically exposed person that is are you an individual who is or has been entrusted with a prominent function.  Y/N
    • Are you linked with such a person (family, close associate) ? Y/N
    • If yes, please indicate the name and the function of the person justifying this status.

POLICY AND PROCEDURE FOR KNOWING THE PLATFORM USER’S BUSINESS AS PART OF CUSTOMER DUE DILLIGENCE (CDD)

POLICY

It is the policy of AC Group to obtain information enabling to assess the purpose and intended nature of every Platform User’s relationship with AC Group. This Know Your Client’s Business information will enable AC Group to maintain our assessment of the on-going money laundering risk, and notice changes or anomalies in the Platform User’s arrangements that could indicate money laundering.
It is the policy of AC Group not to offer its services, or to withdraw from providing its services on the platform, if a satisfactory understanding of the nature and purpose of the Platform User’s business cannot be achieved.

CONTROLS AND PROCEDURES (security management as laid down in the document “Policy AML and Fraud Tools”)

  1. The responsible AC Officer will obtain Know Your Client’s Business information from Studio’s/Performers (both individual and non-individual) on the platform:
    • on acceptance of Studio’s/Performers on any significant change in the Studio’s/Performers agreements such as the size or frequency of transactions, nature of business conducted, involvement of new parties or jurisdictions as an ongoing exercise throughout the relationship with the Platform User.
  2. Know Your Client’s Business information sought from Platform Users will include, but not be limited to:
    • the purpose or need and business justification of the services the Platform User is selling on the platform as a Studio/Performer to the Users and by using the E-wallet for the pay-outs to the Platform Users..
    • the provenance of funds or assets involved in the Platform User’s sales.
    • the nature, size, frequency, source and destination of anticipated transactions of the Studio/Performer (volume and destination of the transactions).
    • the business justification for all uses of structures and entities (if applicable).
    • the counter-parties and jurisdictions concerned.
  3. The information will be obtained by asking the Platform User pertinent questions, and the answers given by the Platform User will be verified where this is possible within the course of normal conduct of the relationship (survey Platform User).
  4. Information provided by the Platform User will be recorded on the Platform User account, to assist with future monitoring of the Platform User relationship (Flag on account monitoring).
  5. Answers not readily verifiable should nevertheless be considered together with other details known about or given by the Platform User to check that all the information is consistent and plausible.
  6. Where answers given by the Platform User are implausible, or inconsistent with other information, or where the Platform User is unwilling to provide satisfactory answers to due diligence enquiries, the responsible AC Officer will consider whether AC Group should commence the relationship or withdraw from the relationship.
  7. Know Your Client’s Business information, or the lack of it, will be taken into account by all staff when considering possible grounds to suspect money laundering.

POLICY AND PROCEDURE FOR ONGOING MONITORING OF THEPLATFORM USERS

AC Group shall in any event monitor the following events and seek for a satisfactory explanation:

  • Change in banking references
  • Change in location
  • With respect to the non-individual Studio’s/Performers: Change in the management/change in beneficial ownership

The audits will be performed at the anniversary date that is the date that the Studio/Performer has registered himself on the platform. An alert will notify the team when the controls must be performed.

The consequence of these audits may be the performance of additional steps (request for additional documentation additional checks…), that must be documented in the file of the Platform Users (made of their information, supporting documents, and AML monitoring information).

These audits can as well lead to a new evaluation of the level of scrutiny applied to the Platform User, even up to the end of the business relationship. Such a decision is taken by the AC Group’s owners, on the advises of the MLRO and the responsible of internal control.

POLICY AND PROCEDURE FOR KEEPING RECORDS OF PLATFORM USER DUE DILIGENCE INFORMATION

POLICY

It is the policy of AC Group to establish and maintain systems to keep records of enquiries made and information obtained while exercising Platform User due diligence for AML purposes, and to ensure that these records are retrievable as required for legal and regulatory stipulations. These records will include but not be limited to details recorded for accounting and business development purposes.

CONTROLS AND PROCEDURES

  1. When information is being collected for AML Platform User, the responsible AC Officer will ensure that:
    • information collected is recorded in a consistent manner in the Platform User account, or other appropriate place, and that records held in different places are cross- referenced where appropriate, so that information is accessible by and comprehensible to other authorized members of staff, including the MLRO
    • all instances are recorded where information requested has not been forthcoming, or explanations provided have not been satisfactory.
  2. AC Group shall have systems to routinely archive records along with AC Group’s accounting records to ensure their availability for a minimum of the legal requirements from the date of the completion of the transaction or enquiry.
  3. AC Group shall have data retrieval systems which facilitate full and rapid retrieval of all relevant records by authorised staff, in order to respond fully to enquiries from financial investigators.
  4. AC Group shall have procedures to ensure that any personal data obtained is processed only for the purposes of preventing money laundering and terrorist financing.
  5. Every document and information collected at the opening of the account, concerning the identity of the Studio/Performer, if applicable its UBO, as well as all of those collected during the business relationship, must be kept during 5 years from the closing of the account. Moreover, each year, the historic of all the transactions performed since the beginning of the year must be kept during 5 whole years. AC Group keeps all the documents in data resulting from their business relationship with the Studio’s/Performers by archiving them according to conditions and modality guaranteeing their integrity, and especially on a permanent support respecting the GDPR rules.
  6. AC Group shall provide new Platform Users with the following information prior to registration on the SNV Platform:
    • a statement that any personal data received in respect of the registration will be processed only for the purposes of preventing money laundering and terrorist financing. (GDPR)
  7. AC Group shall have a procedure to earmark relevant personal data for deletion at the end of the legal retention period unless:
    • it is required for court proceedings
    • the data subject has given express consent to the retention of that data.
  8. For registered accounts on the SNV Platform which have been the subject of a suspicion report, relevant records will be retained separately from AC Group’s routine archives, and not destroyed, even after the legal retention period has elapsed, without confirmation from the MLRO that they are no longer required as part of an enquiry.

POLICY AND PROCEDURE FOR INTERNAL SUSPICION REPORTING

POLICY

It is the policy of AC Group that every member of staff shall remain alert for the possibility of money laundering, and shall report any and every suspicion for which they believe there are reasonable grounds, following AC Group’s procedure.
The expectation placed on each individual member of staff in responding to possible suspicions shall be appropriate to their position in AC Group. No-one is expected to have a greater knowledge and understanding than is appropriate to their role.

CONTROLS AND PROCEDURES

  1. Every member of staff must be alert for the possibility that AC Group’s services could be used for money laundering purposes, or that in the course of their work they could become aware of criminal or terrorist property.
  2. Alertness to the possibility of money laundering must be combined with an appropriate knowledge of Platform User’ normal arrangements so that members of staff become aware of abnormal factors which may represent possible causes of suspicion.
  3. A member of staff becoming aware of a possible suspicion shall gather relevant information that is routinely available to them and decide whether there are reasonable grounds to suspect money laundering. Any additional information acquired, in particular any explanations for unusual instructions or transactions, should be recorded on the accounts registered on the platform in the routine manner, but no mention of suspected money laundering is to be recorded in any such accounts.
  4. The requirement to gather relevant information does not extend to undertaking research or investigation, beyond using information sources readily available within AC Group.
  5. If after gathering and considering routinely available information, the member of staff is entirely satisfied that reasonable grounds for suspicion are not present, no further action should be taken.
  6. A member of staff who on consideration decides that there may be grounds for suspicion shall in normal circumstances raise the matter with the responsible AC Officer. If after discussion they both agree that there are no grounds for suspicion, no further action should be taken.
  7. No member of staff is obliged to discuss a suspicion of money laundering with the responsible AC Officer. They may, if in the circumstances they prefer, contact the MLRO directly without giving a reason.
  8. If following the raising of a possible suspicion by a member of staff, or resulting from their own observations, the responsible AC Officer decides that there are reasonable grounds to suspect money laundering, he or she must submit a suspicion report to the MLRO, in the format specified by the MLRO for that purpose.
  9. An internal suspicion report does not lead to the breach of confidentiality, and no member of staff shall fail to make an internal report on those grounds.
  10. If a suspicion report results from a matter raised by a member of support staff, the responsible AC Officer must advise them in writing that a report has been submitted by reference to the matter discussed on the given date, without including the name of the person(s) suspected. This confirms to the member of staff who raised the matter that their legal obligation to report has been fulfilled. (reporting procedure format)
  11. In the circumstance where any member of staff forms a suspicion of money laundering but the responsible AC Officer does not agree that there are reasonable grounds for suspicion, the member of staff forming the suspicion must fulfil their legal obligation by submitting a money laundering suspicion report to the MLRO, in the format specified by the MLRO for that purpose. The responsible AC Officer must recognise this legal requirement and assist the staff member in fulfilling it.
  12. A member of staff who forms or is aware of a suspicion of money laundering shall not discuss it with any outside party, or any other member of staff unless directly involved in the matter causing suspicion.
  13. No member of staff shall at any time disclose a money laundering suspicion to the person suspected (including an outside party). If circumstances arise that may cause difficulties, the member of staff must seek and follow the instructions of the MLRO.
  14. No copies or records of money laundering suspicion reports are to be made, except by the MLRO who will keep such records secure, and separate from AC Group’s Platform User accounts and other repositories of information.

POLICY AND PROCEDURE FOR FORMAL DISCLOSURES TO THE AUTHORITIES

POLICY

It is the policy of AC Group that the Money Laundering Reporting Officer (or if absent, the deputy MLRO) shall receive and evaluate internal suspicion reports, and decide whether a formal disclosure is to be made to the authorities. If so deciding, the MLRO will make the formal disclosure on behalf of AC Group, using the appropriate mechanism.

CONTROLS AND PROCEDURES

  1. On receipt of a money laundering suspicion report from a member of staff, the MLRO shall acknowledge its receipt in writing, referring to the report by its date and unique file number, without including the name of the person(s) suspected. This confirms to the member of staff that their legal obligation to report has been fulfilled.
  2. The MLRO shall open and maintain a log of the progress of the report. This log shall be held securely and shall not form part of the Platform User account.
  3. Following receipt of a report, the MLRO shall gather all relevant information held within AC Group, and make all appropriate enquiries of members of staff anywhere in AC Group, in order properly to evaluate the report. The MLRO shall then decide whether they personally believe there are reasonable grounds for suspicion, and make a decision on AC Group’s obligation to make a formal disclosure to the authorities.
  4. Before actually making a formal disclosure to the authorities, the MLRO will have to seek advice from AC Group’s owner. AC Group’s owner will have the final decision on whether to make a formal disclosure to the authorities.
  5. All members of staff, anywhere in AC Group, shall respond in full to all enquiries made by the MLRO for the purposes of evaluating a suspicion report. Information provided to the MLRO in response to such enquiries does not breach any confidentiality/professional privilege, and no member of staff shall withhold information on those grounds.
  6. If it has been decided that a formal disclosure to the authorities is required, the MLRO shall make such disclosure by the appropriate means.
  7. The MLRO shall document in the report log the reasons for deciding to make or not to make a formal disclosure.
  8. The MLRO shall where appropriate inform the originator of the internal report whether or not a formal disclosure has been made.
  9. The MLRO shall inform all those, and only those, members of staff who need to be aware of the suspicion in order to protect them and AC Group from possible money laundering offences in connection with any related business.
  10. Following a formal disclosure, the MLRO shall take such actions as required by the authorities in connection with the disclosure.

POLICY AND PROCEDURE FOR BLOCKING/CONTINUING THE ACCOUNT REGISTRED ON THE PLATFORM FOLLOWING A SUSPICION REPORT

POLICY

It is the policy of AC Group that from the moment a suspicion of money laundering arises, the registered account will be blocked. Neither commercial considerations nor the difficulty in responding to the enquiries of the persons registered on the platform on the matter shall be permitted to take precedence over AC Group’s legal obligations in this regard.

CONTROLS AND PROCEDURES

  1. As soon as a member of staff forms or becomes aware of a suspicion of money laundering, the registered account will be blocked.
  2. If there is any likelihood of the awareness that the registered account has been blocked, for example because an anticipated transaction has not gone through, the member of staff concerned must contact the MLRO for instructions on how to handle the matter.
  3. On receipt of a suspicion report, the MLRO shall instruct the originator of the report and any other staff involved to block the registered account giving rise to suspicion
  4. When an registered account has been blocked, the MLRO shall carry out the evaluation of the suspicion report as quickly as possible to decide whether a disclosure must be made to the authorities.
  5. If the MLRO decides that there are not reasonable grounds to suspect money laundering, he or she will give consent for continuing the registered account on his or her own authority.
  6. If the MLRO decides that a disclosure must be made, he or she will request consent to continue from the AC Group’s owner as quickly as possible. The AC Group’s owner will have the final decision on AC Group’s continuation of the registered account.

POLICY AND PROCEDURE FOR AML TRAINING

POLICY

It is the policy of AC Group that recruitment of all new staff will include assessment as described in section 48(2) of the European Money Laundering Regulations. (source PDF 2018 European directives AML). Screening will take place prior to appointment and at regular intervals during the appointment of all staff.
It is the policy of AC Group that all staff who handle the registered accounts, or access to the registered accounts, shall receive anti-money laundering training to ensure that their knowledge and understanding is at an appropriate level, and ongoing training at least annually to maintain awareness and ensure that AC Group’s legal obligations are met.
It is the policy of AC Group that all staff who handle the registered accounts, or access to personal data relating to such accounts, shall receive training on the law relating to data protection to ensure that their knowledge and understanding is at an appropriate level, and ongoing training at least annually to maintain awareness and ensure that AC Group’s legal obligations are met.
The MLRO shall, in co-operation with AC Group’s training officer and data protection officer, ensure that training is made available to staff according to their exposure to money laundering and data protection risk, and that steps are taken to check and record that training has been undertaken and that staff have achieved an appropriate level of knowledge and understanding.
In the light of the seriousness of the obligations placed on each individual by the Law and the Regulations, and the possible penalties, the MLRO shall ensure that information about these personal obligations is available to all members of staff at all times.
The goal of the training is:

  • To develop AML reflexes
  • rise each staff member awareness, in order to maintain their AML reflexes
  • update collective and operational knowledge of the AML risks
  • train the staff members to detect suspicious cases
  • train these staff members to formalize new type cases with potential risks
  • check the appropriate knowledge of the procedures and the subsequent obligations,

The training of all the newly hired staff is part of their integration process, under the responsibility of the head of internal control. The head of compliance hold the training session. The session can be held by web conference.
The training supports and attendance sheets, must be kept for at least 5 years after the departure of the specific collaborator.

CONTROLS AND PROCEDURES

  1. Post appointment, staff assessment according to section 48(2) of the European Money Laundering Regulations will be incorporated into AC Group’s regular staff appraisal process.
  2. The MLRO will, in co-operation with AC Group’s training officer, evaluate alternative AML training methods, products and services in order to make suitable training activities available to all members of staff who handle the registered accounts.
  3. Suitable training will take into account:
    • the need to achieve a level of knowledge and understanding appropriate to the individual’s role in AC Group
    • the need to maintain that level through ongoing refresher training
    • the practicality of assigning different programs to staff with different roles on a risk- sensitive basis
    • the cost and time-effectiveness of the alternative methods and media available.
  4. The training program will include means of confirming that each individual has achieved an appropriate level of knowledge and understanding, whether through formal testing, assessment via informal discussion, or other means.
  5. Special consideration will be given to the training needs of senior management, and of the compliance team.
  6. The MLRO will:
    • inform every member of staff of the training program that they are required to undertake, and the timetable for completion
    • check that every member of staff has completed the training program assigned to them, issuing reminders to any who have not completed to timetable
    • refer to the business owner any cases where members of staff fail to respond to reminders and have not completed their assigned training
    • keep records of training completed, including the results of tests or other evaluations demonstrating that each individual has achieved an appropriate level of competence.
  7. On completion of a training cycle, the MLRO will ensure the continuity of ongoing training while giving consideration to:
    • the effectiveness of the program completed
    • the need to keep training information up to date with changes in laws, regulations,
    • guidance and practice.
  8. The MLRO will determine the training needs of his or her own role, and ensure that he or she obtains appropriate knowledge and understanding as required to fulfill the obligations of the appointment.

POLICY AND PROCEDURE FOR THE MONITORING AND MANAGEMENT OF COMPLIANCE

POLICY

It is the policy of AC Group to monitor our compliance with legal and regulatory AML requirements and conduct an annual independent AML compliance audit, the findings of which are to be considered and appropriate recommendations for action set out.
AC Group’s owner shall provide the necessary authority and resources for the ongoing implementation of a compliant AML regime.

CONTROLS AND PROCEDURES

  1. The MLRO will monitor continuously all aspects of AC Group’s AML policies and procedures, together with changes and developments in the legal and regulatory environment which might impact AC Group’s business-wide risk assessment. Any deficiencies in AML compliance requiring urgent rectification will be dealt with immediately by the MLRO, who will report such incidents to AC Group’s owner when appropriate and request any support that may be required.
  2. The MLRO will facilitate and assist the independent auditor in conducting an annual audit of AC Group’s AML compliance. This report will include:
    • a summary of AC Group’s money laundering risk profile and vulnerabilities, together with information on ways in which these are changing and evolving
    • a summary of any changes in the regulatory environment(s) in which AC Group operates and the ways in which AC Group is affected
    • a summary of AML activities within AC Group, including the number of internal suspicion reports received by the MLRO and the number of disclosures made to the authorities
    • details of any compliance deficiencies on which action has already been taken, together with reports of the outcomes
    • details of any compliance deficiencies on which action needs to be taken, together with recommended actions and management support required
    • an outline of plans for the continuous development of the AML regime, including ongoing training and awareness raising activities for all relevant staff.
  3. Where management action is indicated, AC Group’s owner will decide the appropriate action to be taken.