EXL PB is committed to the prevention of financial crime and has adopted procedures to detect and deter money laundering, terrorist financing or other illegal activities.
It is our policy to deter and, where we can prevent, the use of the EXL PB as a conduit for illegal money laundering activities. Our staff can only implement this policy if they understand the background to it and how it works in the context of our day-to-day business. The success of our policy depends on the vigilance of everyone.
For these policies to be effectively implemented, the Financial Institution and its entire staff need to be:
The Union of Comoros is a member of Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG).
The purpose of the Eastern and Southern Africa Anti-Money Laundering Group (ESAAMLG) is to combat money laundering by implementing the FATF Recommendations. FATF – the Financial Action Task Force – is an inter-governmental body whose purpose is the development and promotion of policies, both at national and international levels, to combat money laundering and terrorist financing.
This effort includes coordinating with other international organizations concerned with combating money laundering, studying emerging regional typologies, developing institutional and human resource capacities to deal with these issues, and coordinating technical assistance where necessary. ESAAMLG enables regional factors to be taken into account in the implementation of anti-money laundering measures. ESAAMLG members participate in a self-assessment process to assess their progress in implementing the FATF Forty Recommendations.
The Union of Comoros is also an observer member of the Inter-Governmental Action Group against Money Laundering in West Africa (GIABA) to give support in matters relating to anti-money laundering and combating the financing of terrorism (AML/CFT).
GIABA is an institution of the Economic Community of West African States (ECOWAS) responsible for facilitating the adoption and implementation of Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) in West Africa. It is also a FATF-Styled Regional Body (FSRB) working with its member states to ensure compliance with international AML/CFT standards.
Further information in this regard, which forms the basis of the policy of EXL Private Bank, can be found at the following link: FATF 40 Recommendations and FATF 9 Special Recommendations.
At EXL PB we only offer our services (e.g., issue of guarantees) to legal entities (individuals or corporate) who have become approved clients of the EXL Private Bank. A potential client is required to go through a thorough verification exercise so that we can establish that they are legitimate.
Although our approved clients are, in general, introduced through agents, it is EXL PB and not the agent who has the responsibility of verifying the identity and legitimacy of the prospective client. As a number of our agents are located in countries which are regarded for money laundering purposes as higher risk – such as Africa and India – we have adopted a high standard for required documentation before a client application will be accepted. This is detailed in the Compliance Agreement.
We additionally check all potential client applicants against international sanctions lists. This verification is completed before we accept the one-time non-refundable processing fee for the compliance procedure.
Our vigilance does not stop upon the admission of a client. Before accepting an application from a client for a guarantee or similar credit, we require documentary proof from the client of the legitimate commercial nature of the business or contract which is to be guaranteed.
This is because we recognize that the risk to EXL PB of being used for improper purposes as described in the examples below.
The process by which criminals attempt to change the identity of “dirty” money (obtained through crime) by “laundering” it so that its true source cannot be traced. Whilst there is no single method of money laundering, there are generally three stages:
Funding or facilitating money laundering and using laundered money are all criminal offenses. Additional offenses connected with money laundering include:
Any individual can commit these offenses if they know (or should have known, measured by the standard of the reasonable person in their position) that the money is from an illegal source. These offenses are punishable by unlimited fines and imprisonment.
It is trite (but true) to say that someone’s intent on illegal activity such as money laundering will not introduce themselves to us in those terms. Whilst generalizations are not always useful, red flags to a suspicious transaction or illegal activity can include:
At EXL PB, the Money Laundering Reporting Officer (“MLRO”) is a member of senior management with the specific responsibility of overseeing the implementation of our policies to prevent financial crime. The MLRO reports directly to the Board of EXL PB.
EXL PB and each member of staff is required by law to report suspicious transactions, via the firm’s MLRO, to ESAAMLG. The individual obligation is satisfied by promptly reporting your suspicions to the MLRO.
EXL Private Bank recognizes the importance of keeping full and accurate records of the steps taken by us to verify our approved clients and applicants. All original documentation is maintained in paper or electronic format for as long as a person remains an approved client and for 6 years thereafter.
EXL PB is responsible for making sure that our staff:
With this in mind, we conduct periodic refresher training for our staff. The MLRO or other senior management are on hand to answer any questions or deal with concerns on this topic
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