1. Purpose
This policy sets out the measures Jadenex applies to prevent the service being used to launder the proceeds of crime, to finance terrorism, to finance proliferation or to evade sanctions.
The policy applies to every account holder, to every applicant and to every member of staff. It is approved by the board and reviewed at least annually.
2. Risk based approach
A business wide risk assessment identifies the money laundering and terrorist financing risk arising from the customer base, the products offered, the delivery channels used and the jurisdictions served. Controls are calibrated to that assessment and the assessment is reviewed at least annually and whenever a material change occurs.
Each customer is assigned a risk rating at onboarding. The rating determines the depth of due diligence applied, the frequency of review and the thresholds at which monitoring alerts are generated.
3. Customer due diligence
Before an account is funded, Jadenex carries out the following.
- Identifies the customer and verifies identity using a government issued identity document checked against a facial image captured at the time of the application.
- Verifies residential address using an independent source or a document dated within the last three months.
- Establishes that the customer is acting on their own behalf and not for an undisclosed third party.
- Screens the customer against sanctions lists, politically exposed person lists and adverse media.
- Records the purpose and intended nature of the relationship.
Where due diligence cannot be completed, the account is not opened, no transaction is carried out and consideration is given to whether a report should be made.
4. Enhanced due diligence
Enhanced measures are applied where risk is higher, including in the following cases.
- The customer is a politically exposed person, a family member of one or a known close associate of one.
- The customer is connected to a jurisdiction identified as presenting a higher risk.
- The pattern of activity is unusual for the profile of the account or lacks an apparent economic purpose.
- Funding derives from a source that screening identifies as carrying elevated risk.
Enhanced measures include obtaining evidence of source of funds and source of wealth, senior management approval before the relationship is established or continued, and more frequent review.
5. Ongoing monitoring
Activity is monitored throughout the relationship against the profile established at onboarding. Screening is repeated whenever a list is updated. Customer information is refreshed on a cycle determined by the risk rating.
Digital asset transfers are screened using blockchain analytics for exposure to sanctioned addresses, to darknet markets, to ransomware, to fraud and to mixing services. An exposure above the defined threshold generates an alert.
6. Suspicious activity reporting
A member of staff who knows or suspects, or has reasonable grounds to know or suspect, that a person is engaged in money laundering or terrorist financing must make an internal report to the nominated officer without delay.
The nominated officer considers each internal report and, where the suspicion is not dispelled, makes an external report to the competent authority. A transaction that would prejudice an investigation is not carried out until the appropriate consent or period has been obtained or has elapsed.
Disclosing to the customer or to a third party that a report has been made, or that an investigation is contemplated or being carried out, is prohibited.
7. Prohibited customers and activity
Jadenex does not accept the following.
- A person subject to sanctions or resident in a sanctioned jurisdiction.
- An anonymous account, an account in a fictitious name or a numbered account.
- A shell bank or a customer known to deal with a shell bank.
- A deposit from a third party or a withdrawal to a third party.
- A transfer to or from a mixing service or a privacy tool designed to obscure the origin of funds, where identified.
8. Training
Every member of staff completes training on joining and at least annually thereafter. Training covers the law, this policy, how to recognise a suspicious indicator, how to make an internal report and the prohibition on disclosure. Completion is recorded and non completion is escalated.
9. Record keeping
Identification records, due diligence records, transaction records, screening results, internal reports and external reports are retained for at least five years from the end of the business relationship or from the date of the transaction, whichever is later, and for longer where a competent authority requires it.
10. Governance and assurance
A nominated officer of sufficient seniority is responsible for the operation of this policy and has direct access to the board. The compliance function is independent of the commercial function.
The framework is subject to independent review. Findings are reported to the board with an owner and a target date, and remediation is tracked to closure.