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AML POLICY

Anti-Money Laundering (AML) Policy

Introduction

At GBM Investment, we are committed to maintaining the highest standards of integrity and transparency in all our operations. We recognize the importance of preventing money laundering, terrorist financing, and other financial crimes. To this end, we have implemented a comprehensive Anti-Money Laundering (AML) Policy in accordance with international standards and the regulatory requirements of the Financial Conduct Authority (FCA).

Objectives

Our AML Policy aims to:

  1. Prevent the use of our services for money laundering or terrorist financing activities.
  2. Identify and mitigate the risks associated with financial crime.
  3. Ensure compliance with applicable laws, regulations, and guidelines.
  4. Safeguard the reputation of GBM Investment and its clients by promoting ethical business practices.
Scope

This AML Policy applies to all employees, directors, and officers of GBM Investment, as well as to our clients and any third parties with whom we conduct business. It covers all aspects of our operations, including account opening, ongoing monitoring, transaction processing, and reporting of suspicious activities.

Key Components

  1. Customer Due Diligence (CDD)

    • We implement strict CDD procedures to verify the identity of our clients before establishing a business relationship. This includes collecting and verifying identification documents, such as passports, driver’s licenses, and proof of address.
    • Enhanced Due Diligence (EDD) is conducted for clients who pose a higher risk of money laundering or terrorist financing, such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.

  2. Ongoing Monitoring

    • We continuously monitor client transactions to identify and report any suspicious activities. This includes the review of transaction patterns, the size and frequency of transactions, and the origin and destination of funds.
    • Any transactions that deviate from the client’s established profile or appear to be unusual will be investigated further.

  3. Reporting and Record Keeping

    • GBM Investment is committed to complying with all reporting obligations under applicable laws. Suspicious Activity Reports (SARs) are filed with the relevant authorities whenever there is a suspicion of money laundering or terrorist financing.
    • We maintain detailed records of all transactions, client identification data, and communications for a minimum of five years. These records are securely stored and readily accessible for regulatory inspections and audits.

  4. Training and Awareness

    • All employees of GBM Investment are provided with regular training on AML regulations, red flags for money laundering, and the procedures for reporting suspicious activities. This ensures that our staff is well-equipped to detect and prevent financial crime.
    • Our training program is updated regularly to reflect changes in laws, regulations, and emerging risks.

  5. Risk Assessment

    • We conduct regular risk assessments to identify potential vulnerabilities in our business operations that could be exploited for money laundering or terrorist financing. This includes evaluating the risk posed by our clients, products, services, and geographic locations.
    • The results of these risk assessments are used to refine our AML controls and procedures continuously.

  6. Third-Party Due Diligence

    • GBM Investment requires that all third-party service providers, including agents and partners, adhere to similar AML standards. We conduct due diligence on third parties to ensure they are compliant with AML regulations and are not involved in any illegal activities.

  7. Internal Controls and Governance

    • We have established robust internal controls to enforce our AML Policy effectively. This includes the appointment of a dedicated Money Laundering Reporting Officer (MLRO) who is responsible for overseeing the implementation of our AML program and ensuring compliance with all regulatory requirements.
    • Our Board of Directors is regularly updated on AML matters and is responsible for ensuring that the necessary resources are allocated to maintain an effective AML program.
Consequences of Non-Compliance

GBM Investment takes violations of this AML Policy seriously. Any employee or client found to be involved in money laundering, terrorist financing, or any related illegal activities will face disciplinary action, which may include termination of employment, suspension of services, and reporting to the relevant authorities.

Continuous Improvement

We are committed to continually improving our AML Policy to address new threats and challenges in the financial landscape. We regularly review and update our AML procedures to ensure they are effective and in line with the latest regulatory developments.

Conclusion

GBM Investment is dedicated to maintaining a safe and secure financial environment for all our clients. Our comprehensive AML Policy is designed to protect the integrity of our operations and prevent financial crimes. By adhering to these principles, we ensure that our clients can trade with confidence, knowing that we are committed to upholding the highest standards of compliance and ethical conduct.