Anti-Money Laundering Strategy
This policy explains our individual responsibility in complying with anti-money laundering and counter–terrorists financing laws (“AML Laws”) around the world and ensuring that any third parties that we engage to act on our behalf, do the same.
- Anti-Money Laundering Policy Statement
- It is Sway Markets Pty Ltd’s policy to prevent the misuse of the Sway Markets Pty Ltd services for money laundering and/or terrorism financing purposes. Sway Markets Pty Ltd is committed to full compliance with all applicable laws and regulations regarding the prevention of money laundering and terrorism financing.
- For these purposes, money laundering means the conversion, transfer, concealment or retention of any funds or property knowing that the funds or property are derived from any activity that constitutes a criminal offence SVG laws. The term money laundering should be interpreted as including trade-based money laundering and terrorist financing which refers to the process of disguising the proceeds of crime and moving value through the use of trade transactions in an attempt to legitimize their illegal origins or finance their activities.
- If Sway Markets Pty Ltd, its personnel and/or its services are misused for money laundering or terrorism financing, even inadvertently, the Company could possibly be subject to penalties. Such activities could also jeopardize the Company’s reputation in local and global markets.
- Sway Markets Pty Ltd has a considerable importance in initiatives to fight financial crime and will always cooperate and provide all possible assistance to the authorities in this effort.,
- Sway Markets Pty Ltd has adopted a Policy Manual and a Procedures Manual which provide the basis for all employees to comply with all relevant requirements in this area and assist employees in maintaining the reputation of the Company. Employees should be alert to the possibility of the Company being inadvertently involved in the activities of third parties who may seek to use its services to obscure the source or beneficial ownership of money or other financial property.
- This Policy Statement sets out the principles that are of application in Sway Markets Pty Ltd, including offices and branches located overseas.
- Minimum Standards
- This Policy statement is meant to set the minimum standards to which Sway Markets Pty Ltd will adhere to. In some circumstances the Sway Markets Pty Ltd policies and procedures can set a higher standard than that established by the applicable law. Under all circumstances Sway Markets Pty Ltd will conduct its business in compliance with the following general principles:
- ▪Ensuring that Sway Markets Pty Ltd is not used for or involved in money laundering and terrorist financing.
- ▪Maintaining written AML policies and procedures, a system of internal controls to ensure ongoing AML compliance by a designated person(s), take appropriate action once suspicious activity is detected and a proper and thorough process for filing Suspicious Transaction Report is followed.
- ▪Ensuring compliance with applicable anti-money laundering and terrorist financing laws and regulations in each jurisdiction that is in accordance with the recommendations of the FATF.
- ▪Ensuring that the Company’s anti-money laundering policies are applied to all business entities.
- ▪Reporting all identified suspicious activities to the competent authorities to the extent that it can do so under all applicable foreign and domestic laws.
- ▪Monitoring compliance with the Bank’s anti-money laundering policies.
- ▪Retaining all customer related documents for a period as specified per the local laws
- ▪Cooperating fully with law enforcement and regulatory agencies to the extent that it can do so under all applicable foreign and domestic laws.
- ▪Providing regular training to staff on Know Your Customer and Anti-Money Laundering policies and new AML laws and regulations.
- ▪Conducting enhanced due diligence for high risk customers.
- ▪Obtaining all account opening documentation requirements as per the applicable legislation.