AML Policy

Know Your Customer (KYC) and/or Know Your Customer Counter Party” (KYCC) Policy

KYC and KYCC are effective defenses against money laundering andr terrorist financing.

Send Exchange ensures that the key information and documents to support effective KYC and KYCC include:

• Complete name of Remitter or Remitting Company as per the identity card/Trade License Name)
• Complete address
• Contact number
• ID details (Type of ID & Date of issue & expiry date)
• Job profile/line of business
• Source of funds
• Purpose of transaction
• Relationship with the beneficiary
• Ultimate Beneficial Owner (UBO)
• Copy of valid ID

Send Exchange staff shall always sight the original ID from the Remitter, and initial a copy of the ID as “True Copy”.

In rare events or incidences where a Customer fails to provide adequate KYC information, or appears hesitant/unwilling to provide information as required to establish adherence to KYC norms, Send Exchange shall not proceed with a transaction for such as Customer, and flag the case as a High Risk customer. Such cases are marked for reporting to the Regulator through Suspicious Transaction Report (STR), and for increased monitoring.

Due Diligence (DD)

Send Exchange shall do due diligence before on boarding the customer or establishing business relationship with the correspondent banks, service providers and business partners.

Enhanced Customer Due Diligence (ECDD)

Send Exchange shall perform Enhanced Due Diligence in the following scenarios:

Before onboarding the customers dealing with:

• Jewelry and precious stones
• Real Estate
• Luxury items
• Auction houses
• Non-resident account holders/visitors
• Trust, charities, and not for profit organisation

The customers of high-risk countries/products/services etc. Politically Exposed Persons (PEPs) If the customer/transaction found to be suspicious/unusual. Any other suspicious cases alerted by the system based on the rule violation(s). The above scenarios are reviewed periodically and updated as required.

Screening

Send Exchange’s AML solution has the capability to store the watch lists such as OFAC, UN, EU, HMRC and the list of names issued by Bank of England and Law enforcement.

Internal Black list: Additionally, to support and comply with demand from competent authorities as required, the system has the capability to maintain an internal blacklist to “add” or “remove” the names as communicated by the authorities.

The lists are updated on daily basis if there are notices/alerts from regulatory authorities for the purpose of screening the names to identify the individuals, entities, organizations who may pose a high risk to the global community/financial systems.

Reporting of Suspicious Transaction Report (STR)

Send Exchange shall file suspicious transaction report to Regulator if there are reasonable grounds to suspect that the proceeds are from the outcome of any of the illegal activities and/or the transaction is intended for terrorist financing/activities.

Prohibited Business/Relationships

Send Exchange shall not enter into a business relationship with any of the shell company/ shell bank/ shell service provider. For the existing customers, during the course of business relationship if there are reasonable grounds to believe that the client/service provider involve into any of the illegal activities, relationship with such clients / service providers, will be suspended/terminated with immediate effect and will be reported to the regulatory authority.

Sanction Policy

Send Exchange shall not conduct any transaction to/from any Sanction body and will not undertake/accept any transaction to/for individual, entity and/or (SDN’s) which are black listed by the local and/or any of the international regulatory authorities.

PEP Transactions

Financial transactions of Politically Exposed Person generally possess high risk due to the possible involvement in bribery and/or corruption. Hence, onboarding of PEP customer requires compliance clearance and senior management approval. At the transactional stage, it requires proper satisfactory supporting documents to substantiate the transaction. Failure to comply with the supporting documents by the customer shall be reported to the regulator.

Anti-Bribery and Corruption (ABC) and Anti- Fraud

Send Exchange will not tolerate any form of bribery, corruption and/or fraud. All Send Exchange employees are strictly prohibited from having any involvement in the act of such activities. Any non-compliance to this act shall attract disciplinary action.

Correspondent Banking/Agents Relationship

Send Exchange shall enter into a correspondent banking/Agent relationship only after considering the following factors and with the approval of the Management:

• After conducting proper KYC/Due Diligence.
• Ensuring that the Correspondent Bank/Agent has a documented AML/CTF policies and procedures.
• Ensuring that the Correspondent Bank/Agent is registered and monitored by a regulatory authority.
• Ensuring that the Correspondent Bank/Agent had not been fined for AML/CTF/ any other major non-compliance.
• Ensuring that the Correspondent Bank/Agent has a physical existence in their home country.

In addition to the above, Send Exchange will also obtain an approval from the Regulator of the UK before commencement of relationship with them.

Wolfsberg /Self-attested KYC/AML/CTF Questionnaire

Send Exchange has a self-attested KYC/AML/CTF Questionnaire drafted in line with the Wolfsberg KYC principle, regulatory requirements of the UK and other international regulatory bodies. These questionnaires are subject to frequent reviews and modifications to accommodate the regulatory and/or industry changes.