What is Money Laundering?
Money laundering is the process of making illegally-gained proceeds (i.e. “dirty money”) appear legal (i.e. “clean”). This is typically done by disguising the proceeds as legitimate funds through a series of transactions that make it difficult to trace the source of the money.
Money laundering can take many forms and involve multiple steps, but it typically includes three stages: placement, layering, and integration.
- Placement: The initial introduction of “dirty” money into the financial system. This can be done by physically depositing cash into a bank account, or by using other methods such as wire transfers, which make it more difficult to trace the money back to its illegal origins.
- Layering: This is the separation of “dirty” money from its source through a series of financial transactions designed to complicate the trail and make it more difficult to trace. This can include transferring money through multiple bank accounts, exchanging it for other assets, or moving it through offshore accounts.
- Integration: The final stage of money laundering, in which “clean” money is returned to the launderer in a form that can be easily used, such as by returning the funds to the launderer’s bank account, investing the money in real estate or other assets, or using it to purchase businesses.
Money laundering is a criminal offence in many countries, it helps to conceal the proceeds of crime and fund illegal activities, also it can be a serious problem for the financial system. Regulations have been established in most countries to combat money laundering and to require financial institutions to adopt procedures to identify and report suspicious activity.
Purpose
The purpose of this policy is to prevent Duke Sterling and its employees from being used for money laundering activities and to comply with all applicable Anti-Money Laundering laws and regulations.
Policy Statement
Duke Sterling will take all necessary measures to prevent money laundering by implementing and maintaining an effective Anti-Money Laundering (AML) program. This program will include, but is not limited to, the following:
- Customer Due Diligence (CDD) procedures to identify customers and beneficial owners of customers and to assess the risk of money laundering or terrorist financing.
- Record-keeping procedures to maintain accurate and complete records of all transactions and customer identification information.
- Reporting suspicious activity to the appropriate government authorities, including the filing of Suspicious Activity Reports (SARs) as required by law.
- Staff training to ensure that all employees understand their obligations under this policy and are able to recognize and report suspicious activity.
Customer Due Diligence
- Identification and verification of the identity of all customers and beneficial owners of customers in accordance with applicable laws and regulations.
- Assessing the risk of money laundering or terrorist financing presented by each customer, taking into account the customer’s location, type of business, and transaction patterns.
- Enhanced due diligence for higher-risk customers and transactions.
Record-keeping
- Maintaining accurate and complete records of all customer identification information and transaction records.
- Retaining these records for a minimum of five years after the account is closed or the transaction is completed.
Reporting Suspicious Activity
- Reporting suspicious activity to the appropriate government authorities, including the filing of Suspicious Activity Reports (SARs) as required by law.
- Training employees to recognize and report suspicious activity, and ensuring that all employees understand their obligations to report suspicious activity.
Compliance
- Regularly reviewing and updating the AML program to ensure compliance with all applicable laws and regulations.
- Ensuring that all employees understand and comply with the AML policy and program.
Consequences of non-compliance
- Violations of this policy may result in disciplinary action, up to and including termination of employment.
- Failure to comply with applicable Anti-Money Laundering laws and regulations may result in fines, penalties, and/or criminal prosecution.
Overall
- Duke Sterling shall keep updating the AML policy and the AML program as per the legal and regulatory requirements.
- The senior management of Duke Sterling shall take the responsibility of compliance and implementation of this policy