AML Policy | Right Choice Finance

RIGHT CHOICE LENDING CORPORATION


ANTI-MONEY LAUNDERING

OPERATING MANUAL

(Updated February 2018)


  1. INTRODUCTION

The Board of Directors, Management, and Staff of RIGHT CHOICE LENDING CORPORATION (the “Company”) hereby commit themselves to establish ways and means to detect and prevent the commission of money laundering activities prohibited under the Anti-Money Laundering Act of 2002 (Republic Act No. 9160), as amended by R.A. No. 9194, through the acquisition of the products of, or availment of the services offered by, the Company; and to institutionalize a reporting system through which money laundering activities will be reported to the law enforcement agencies concerned.

This Anti-Money Laundering Operating Manual (“Manual") aims to make an appropriate, comprehensive and effective compliance policy for the Company.

  1. DESCRIPTION OF MONEY LAUNDERING
  1. Money laundering is a process intended to mask the benefits derived from serious criminal offenses or criminal conduct as described under the Act, so that they appear to have originated from a legitimate source.
  1. Generally, the process of money laundering comprises three stages, during which there may be numerous transactions that could alert a Regulated Intermediary to the money laundering activity:
  1. Placement - the physical disposal of cash proceeds derived from illegal
  1. Layering -separating illicit proceeds from their source by creating complex layers of financial transactions designed to disguise the audit trail and provide anonymity.
  2. Integration - the provision of apparent legitimacy to criminally derived If the layering process has succeeded, integration schemes place the laundered proceeds back into the economy in such a way that they re-enter the financial system appearing to be normal business funds.

III. BASIC PRINCIPLES & POLICIES TO COMBAT MONEY LAUNDERING

In pursuing its commitment to assist in the detection, prevention, and reporting of money laundering activities, the Company shall be guided by the following principles:

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  1. Know your customer. It shall know its customers by obtaining satisfactory evidence of their identity and having effective procedures to verify the authenticity of the information furnished by new customers. The Company shall also maintain the Information Sheet required to be filled up by clients and have it updated on a regular basis.
  1. Compliance with laws. It shall ensure that its business is conducted in conformity with high ethical standards, that laws and regulations are adhered to, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.
  1. Cooperation with law enforcement agencies. Subject to the legal constraints relating to customer confidentiality, it shall cooperate fully with law enforcement agencies by, among others, taking appropriate measures allowed by law if there are reasonable grounds for suspecting money laundering. For purposes of the Anti-Money Laundering Act of 2001, as amended, disclosure of information regarding suspicious transactions and covered transactions shall be made to the Executive Director, Anti-Money Laundering Council, 5 th Floor EDPC Building, Bangko Sentral ng Pilipinas.
  1. Policies, procedures and training. It shall adopt policies consistent with the principles set out in this Manual, and ensure that its staff, wherever located, are informed of these policies and adequately trained in matters covered herein. To promote adherence to these principles, the Company shall implement specific procedures for customer identification, record keeping and retention of transaction documents and reporting of covered and suspicious transactions.
  1. CUSTOMER IDENTIFICATION
  1. General
  1. Establishment of Customer Identification Program . The Company, as part of its anti-money laundering compliance program, hereby establishes a Customer Identification Program that shall outline the pre-qualification requirements for proper identification of clients as well as their financial capacity.
  1. Notice to Prospective Clients. Prospective clients shall be made aware of the Company’s explicit policy that business transactions will not be conducted with applicants who fail to provide evidence of their identity or whose identity papers are fraudulent or unverifiable.
  1. Proof of Identity. The Company shall obtain satisfactory evidence of the true and full identity, representative capacity, domicile, legal capacity, occupation or business purposes of its clients, as well as other identifying

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information on those clients, whether they be occasional or usual, through the use of documents such as, but not limited to:

  1. Identity documents, such as passports, birth certificates, driver’s licenses, employment identification cards, and such other similar documents whose authenticity is verifiable from the institution issuing the same.

The identifying documents should provide evidence of true name or names used, permanent address, date of birth, nationality, and office address. They should include at least one bearing a photograph and be pre-signed. The identifying documents that are considered most reliable are official identity cards and passports. While identification documents that are easily obtained in any name, e.g., medical cards, credit cards and student identification cards may be used, they should not be accepted as the sole means of identification.

  1. Incorporation and partnership papers, for corporate accounts. These documents should be certified as true copies from the issuing government agency.
  1. Notarized special authorizations for representatives
  1. Other pertinent and reasonable documents as may be deemed necessary under the circumstances prevailing at the time the customer’s account is opened.

Where initial checks fail to identify the applicant or give rise to suspicions that the information provided by him is false, additional verification measures shall be undertaken to determine whether to proceed with the business. Details of the additional checks are to be recorded.

  1. Identification of Clients of Acquired Companies. The same policy of requiring clients to submit proof of their identity shall apply when the Company acquires the business of another financial sector company or institution covered by SEC rules and regulations on Anti-Money Laundering, either in whole or as a product portfolio. However, it is not necessary for the existing customers of such acquired businesses to be reidentified, provided that:
  1. all customer account records are acquired with the business; and
  1. due diligence inquiries do not raise any doubt as to whether the anti-money laundering procedures previously adopted by the acquired business have satisfied Philippine requirements.
  1. Verification and Reidentification. If, during the business relationship with any customer, the Company shall have reason to doubt:
  1. the accuracy of the information relating to the customer's identity;
  1. that the customer is the beneficial owner; or

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  1. the intermediary's declaration of beneficial ownership, or
  1. if there are any signs of unreported changes,

it shall take further measures to verify the identity of the customer or the beneficial owner, as applicable, including, but not limited to, the following:

  1. referral of names and other identifying information to criminal investigating authorities; and/or,
  • review of disciplinary history and disclosure of past relevant sanctions.
  1. Account Names. All customer accounts shall be maintained only in the name of the account holder. The Company shall not open or keep anonymous accounts, fictitious names accounts, incorrect name accounts and similar accounts.
  1. Regular Updating and Verification. All material information with respect to the Company’s customers shall be kept current and accurate through the conduct of regular verification and updates.
  1. Individual Customers
  1. Information to be Obtained. The following information shall be obtained from all individual applicants:

name and/or names used; present address;

permanent address; mailing address;

date and place of birth; nationality;

nature of work, name of employer, or nature of self-employment or business;

tax identification numbers, Social Security number or Government Service and Insurance System number;

specimen signature; sources of funds.

  1. Original Copies of Identity Documents. Applicants who present only photocopies of identifications and other documents shall be requested to produce the original documents for verification purposes.

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  1. Verification Without Face-to-Face Contact .
  1. Whenever possible, prospective clients should be interviewed personally.
  1. Particular care, on the other hand, shall be taken in opening accounts via the Internet, post or telephone, or other such instances that may give rise to verification without face-to-face contact.
  1. In all instances, the customer identification procedures for non-face-to-face verification shall be as stringent as those for face-to-face verification.
  1. To verify the identity of prospective clients where there is no face-to-face contact, the following means shall be utilized:
  1. telephone contact with the applicant at an independently verified home or business number;
  1. subject to the applicant's consent, telephone confirmation of the applicant's employment with the employer's personnel department at a listed business number;
  • salary details appearing on recent bank statements, income tax returns or any other document evidencing compensation;
  1. confirmation of the address through an exchange of correspondence or by other appropriate methods.
  1. An initial deposit check drawn on another financial institution regulated by the Bangko Sentral ng Pilipinas will provide additional comfort.
  1. For non-Philippine residents who wish to open accounts without face-to-face contact, documents as enumerated in Section IV.A.3. issued by foreign authorities may be submitted, duly authenticated by the Philippine Consulate where such foreign authorities are located. Said non-Philippine resident shall, however, be made aware of the general policy that the Company will refuse to enter into any business dealings with customers who have not been properly identified or whose identity papers are not verifiable.
  1. No new accounts shall be opened and created without face-to-face contact unless full compliance with the requirements of Section IV.B.1 and 2. above are met.
  1. Single Proprietorships, Corporations and Partnerships
  1. Background Check. Before establishing a business relationship, a company search and/or other commercial inquiries shall be made to ensure that the corporate/other business applicant has not been, or is not in the process of being dissolved, struck off, wound-up or terminated. In

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the event of doubt as to the identity of the company or its directors, or the business or its partners, a search or inquiry with the Securities and Exchange Commission or the relevant Supervising Authority/Regulatory Agency shall be made.

  1. Documentary Requirements. The following relevant documents shall be obtained in respect of corporate/other business applicants that are regulated in the Philippines:
  1. Copies of the Certificate of Registration issued by the Department of Trade and Industry, for single proprietorships, or by the Securities and Exchange Commission, for corporations and partnerships, including Articles of Incorporation or Certificate of Partnership, as appropriate, copies of the By-Laws and latest General Information Sheet, which lists the names of directors/partners and principal stockholders, and secondary licenses, if any; and other documents such as, but not limited to clearance/certification from the Securities and Exchange Commission that the company is active and compliant with the latter’s reportorial requirements.
  1. The originals or certified copies of any or all of the foregoing documents, where required, should be produced for verification.
  1. Sworn statement as to existence or non-existence of beneficial owners.
  1. Appropriate directors' resolutions and signed application forms or account opening authority containing specimen signatures.
  1. Where necessary, additional information about the nature of the business of clients, copies of identification documents of shareholders, directors, officers and all authorized signatories may also be required. These information may be, but shall not be limited to, the following:
  • Company profile (A brief history)
  • Address, telephone numbers and fax numbers; website and email address, if any
  • List of major projects as supported by product profile, pictures, etc.
  • Organizational chart with bio-data of officers and key personnel with 2” x 2” pictures
  • Latest audited financial statements with certified true copy of the Annual Income Tax Return
  • Bank credit line
  • Photocopy of bank accounts and latest bank statements
  • Location map of company office and major projects
  1. Additional Requirements for non-Philippine Companies. For companies, businesses or partnerships registered outside the Philippines, comparable documents are to be obtained, duly

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authenticated by the Philippine Consulate where said companies are located.

  1. Reverification and Reidentification. If significant changes to the company structure or ownership occur subsequently, or suspicions are aroused by a change in the payment profile through a company account, further checks are to be made on the identities of the new owners.
  1. Shell Companies
  1. Transactions with Shell Companies. Considering the nature of the so called “shell companies” which are legal entities which have no business substance in their own right but through which financial transactions may be conducted, and, as such, are more likely to be used as conduits for money laundering activities, the Company will exercise due care in dealing with said companies.
  1. Additional Requirements for Shell Companies. In addition to the submission of the documentary requirements for corporations and partnerships, shell companies will likewise be required to submit (i) a Board of Directors’ Certification as to the purposes of the owners in purchasing the shell company, and (ii) satisfactory evidence of the identities of the beneficial owners thereof.
  1. Trust, Nominee and Fiduciary Accounts
  1. Determination of Nature of Ownership of Account. Before the opening of accounts applied for, it shall first be established whether the applicant for business relationship is acting on behalf of another person as trustee, nominee or agent.
  1. Proof and Nature of Representative Capacity. Should it be established that an applicant for business relationship is only acting on a representative capacity, satisfactory evidence of the identity of such agents and authorized signatories, as well as the nature of their trustee or nominee capacity and duties, shall be obtained.
  1. Representative Capacity in Violation of Laws. Where there should be any doubt as to whether the trustee, nominee or agent is being used as a dummy in circumvention of existing laws, further inquiries shall immediately be undertaken to verify the status of the business relationship between the parties. If satisfactory evidence of the beneficial owners cannot be obtained, the Company shall have the option of not proceeding with the business, or, to so proceed with the further obligation that it will put its misgivings on record and give extra attention to monitoring the account in question.

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  1. Accounts Opened by Professional Partnerships for Clients. Where a firm of lawyers or accountants opens the account, reasonable inquiries about transactions passing through the subject accounts that give cause for concern should likewise be made, and, if warranted, to report said suspicious transactions to the proper authorities.
  1. Transactions Undertaken on Behalf of Account Holders or Non-Account Holders
  1. Transactions on Behalf of Account Holders. Where transactions are undertaken on behalf of account holders, particular care shall be taken to ensure that the person giving instructions is authorized to do so by the account holder.
  1. Transactions on Behalf of Non-Account Holders. Transactions undertaken for non-account holders demand special care and vigilance. Where the transaction involves significant amounts, the customer shall be asked to produce positive evidence of identity, including nationality, especially in cases where the client is not a Filipino, the purposes of the transaction, and the sources of the funds used therefor.
  1. RECORD KEEPING
  1. Documentation on customer relationships and transactions shall be properly prepared and maintained such that:
  1. the requirements of the Anti-Money Laundering Act are fully met;
  1. any transaction effected through the Company can be reconstructed and from which the Anti-Money Laundering Council (created under the Anti-Money Laundering Act) will be able to compile an audit trail for suspected money laundering, when such a report is made to it;
  1. the Company can satisfy within a reasonable time any inquiry or order from the Anti-Money Laundering Council as to disclosure of information, including, but not limited to, whether a particular person is the customer or beneficial owner of transactions conducted through the Company.
  1. 2 . Records Retention Periods. The following document retention periods shall be followed:
  1. All records of all transactions, especially customer identification records, shall be maintained and safely stored for five (5) years from the dates of transactions.
  1. With respect to closed accounts, the records on customer identification, account files and business correspondence, shall be preserved and

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safely stored for at least five (5) years from the dates when they were closed.

  1. Form of Records for Retention. Transaction documents may be retained as originals or copies, or in electronic form, provided that such forms are admissible in court, pursuant to the Revised Rules of Court and the E-Commerce Act and its Implementing Guidelines.
  1. Effect of Ongoing Investigation on the Retention Periods. Records relating to ongoing investigations or transactions that have been the subject of a disclosure shall be retained beyond the stipulated retention period until it is confirmed that any investigation thereon has been closed.
  1. Records Officers. The Company shall designate at least two (2) persons responsible in the safekeeping of all records required to be maintained herein. Any change in the designated records officers shall be reported to the Securities and Exchange Commission.

Following is a summary of the books and records maintained on a current basis with the corresponding personnel assigned to verify the accuracy and completeness of the said books/records:

BOOKS AND RECORDS

Accountable Person

Audited Financial Statements

(Finance Head)

General Information Sheet

(Corp Secretary)

Filed Returns to BIR

(Accounting Officer)

  • Income Tax Return (1702Q and 1702)
  • Vat Remittances Return (2550M and 2550Q)
  • Creditable Tax Remittances Return (2307)
  • Withholding Tax Remittances Return (1601E and 1601C)
  • Alphabetical list of Employees (Compensation)
  • Alphabetical List of Taxes Withheld (Suppliers and Contractors)
  • Inventory Report

Computerized Books of Accounts and Journals (Acctg Personnel)

  • Journal Voucher Register
  • Check Voucher Register
  • Payable voucher Register
  • Journal voucher
  • Payable voucher
  • Check voucher
  • Trade and Other Receivable
  • Trade and Other Payables
  • Customer Advances and Deposits
  • Due to/from Affiliates
  • Property and Plant and Equipment schedules

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Bank reconciliation

Project Contracts Monitoring

Notice To Proceed issued by Client

Notice To Proceed issued to sub-contractors

Project Costing per Contract

Sub-contractor Company Profile and

(Acctg Personnel)

(Acctg Personnel)

(Acctg Personnel)

(Acctg Personnel)

(Acctg Personnel)

(Acctg Personnel)

and Monitoring Officer)

201 file (Personnel files)

SEC Circulars

(HR personnel)

(Acctg Personnel)

It is important that any material irregularity or documents lacking are noted and reported for immediate rectification correction. This report is submitted to the one maintaining the document/file and the approving officer.

  1. COVERED AND SUSPICIOUS TRANSACTIONS
  1. Report on Covered Transactions. Where a transaction involving an amount exceeding Five Hundred Thousand Pesos (P500,000.00) is made, the Company shall file with the Anti-Money Laundering Council, copy furnished the Securities and Exchange Commission, the mandatory Covered Transaction Report, in substantially the same form as Annex “A” hereof, and, where appropriate, shall clarify the economic background and purpose of the transaction or business relationship if its form or amount appears unusual in relation to the business or financial capacity of the customer and the customer has not been properly identified, or if the economic purpose or legality of the transaction is not immediately clear, as where there is no underlying legal, trade obligation, purpose, origin or economic justification, or where the transaction is unusually large and complex. The Covered Transaction Report shall be signed by the staff or officer who entertained or secured the account and a senior officer not less than the position of the Senior Manager.
  1. Report on Suspicious Transactions. Where the transaction or transactions do not fall within the threshold amount provided in the definition of a covered transaction under the Anti-Money Laundering Act (as amended), and there are reasonable grounds to believe that the source of the funds arise from, or are in anyway related to, an unlawful activity, and that any of the following circumstances exists:
  1. there is no underlying legal or trade obligation, purpose or economic justification;
  1. the client is not properly identified;
  2. the amount involved is not commensurate with the business or financial capacity of the client;

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  1. taking into account all known circumstances, it may be perceived that the client’s transaction is structured in order to avoid being the subject of reporting requirements under the Act;
  1. any circumstance relating to the transaction which is observed to deviate from the profile of the client and/or the client’s past transactions with the covered institution;
  2. the transaction is in any way related to an unlawful activity or offense under this Act that is about to be, is being or has been committed; or
  1. any transaction that is similar or analogous to any of the foregoing;

A Suspicious Transaction Report, in substantially the same form as Annex “B” hereof, shall be filed before the Anti-Money Laundering Council, copy furnished the Securities and Exchange Commission. For this purpose, due diligence shall be exercised through the implementation of adequate systems for identifying and detecting suspicious transactions.

  1. Suspicious Transactions Defined. The suspicion relates to a transaction considering all the circumstances of the transaction. As a general principle, any transaction which tends to cause a feeling of apprehension or mistrust about the lawfulness of the transaction considering (i) its unusual nature or circumstances, or (ii) the person or group of persons with whom the transaction was made and considering further all other relevant factors including knowledge of the person's or persons' business or background (as well as behavioral factors); should be reported as a suspect transaction.

An indicative list of suspicious transaction subject to the reportorial obligation hereunder, although in no case exhaustive, is attached herewith as Annex “C”. Identification of any of the transactions listed should prompt initial enquiries and, if necessary, further investigations on the source of funds. It is left to the better judgment of the Company to gauge the nature of each and every transaction that they would be involved in.

VII. REPORTORIAL REQUIREMENTS

  1. Reporting System; Reporting Officer/Unit. A system for the mandatory reporting of covered and suspicious transactions shall be instituted, including the designation of at least one (1) reporting officer, or, in the alternative, a reporting unit from among the Company’s departments, who will be made responsible for making the reports to the Anti-Money Laundering Council. Such system shall likewise ensure that where urgent disclosure is required, particularly when the account concerned is part of an ongoing investigation, an initial notification shall be made by telephone to the Executive Director, Anti-Money Laundering Council, Bangko Sentral

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ng Pilipinas. To the extent practicable, the reporting system shall work as follows:

  1. Where any employee or personnel, director or officer of the Company knows that a client has engaged in any of the predicate crimes under the Anti-Money Laundering Act, the matter must be promptly reported to the Reporting Officer/ Unit within the organization who, in turn, must immediately report the details to the Anti-Money Laundering Council.
  1. If there are reasonable grounds to suspect that the customer has engaged in an unlawful activity, the Reporting Officer/Unit, on receiving such a report, must promptly evaluate whether there are reasonable grounds for such belief and must then immediately report the case to the Anti-Money Laundering Council unless the officer/unit considers, and records an opinion, that such reasonable grounds do not exist.
  1. Reporting Period. Reports on mandatory covered and suspicious transactions must be done within ten (10) working days after initial detection of facts that may constitute a basis for filing such reports
  1. Confidentiality of Reports. The Company, as well as its directors, officers, and employees, shall not warn customers when information relating to them is being reported to the Anti-Money Laundering Council. Neither shall such information be communicated, directly or indirectly, to any other person other than the Anti-Money Laundering Council. Any violation of this confidentiality provision shall render the person responsible therefor liable for criminal, civil and administrative sanctions under the Anti-Money Laundering Act.
  1. Record of Events Reported to Reporting Officer/Unit. The Company shall maintain a complete file on all transactions that have been brought to the attention of the Reporting Officer/Unit, including transactions that are not reported to the Anti-Money Laundering Council.
  1. Register of Covered Transactions. A register of all covered transactions which are not reported to the Council pursuant to AMLC Resolution No. 292, Series of 2003 shall likewise be maintained. The register shall contain details of the date on which the report is made, the person who made the report to the Compliance Officer, and information sufficient to identify the relevant papers related to said reports.

VIII. INTERNAL CONTROL AND PROCEDURES

  1. Subject to the approval of the Securities and Exchange Commission, the Company shall establish and implement internal control procedures aimed at preventing and impeding money laundering. Such procedures shall, among other things, ensure that all the Company’s officers and employees are aware of the provisions of the law, its implementing rules

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and regulations, as well as all reportorial and compliance control and procedures that shall be established by the Anti-Money Laundering Council, the Securities and Exchange Commission, as well as, internally, by the Company itself.

These internal policies and procedures shall cover:

Communications of firm policies relating to money laundering, including timely disclosure of information and internal audits to ensure compliance with policies, procedures and controls relating to money laundering;

Account opening and customer identification, including requirements for proper identification;

Maintenance of records;

Compliance with the requirement of the Anti-Money Laundering Act and all rules issued in connection thereto; and,

Cooperation with the Securities and Exchange Commission and other relevant Authorities.

Furthermore, written internal reporting procedures which shall:

  1. Enable all the Company’s directors, officers, employees, and key staff to know to whom they should report any knowledge or suspicion of money laundering activity;
  1. Ensure that there is a clear reporting chain under which suspicions of money laundering activity will be passed to the appropriate person/unit, duly identified and designated as the Reporting Officer/Unit.
  1. Require the Reporting Officer/Unit to consider any report in the light of all relevant information available to the Officer/Unit for the purpose of determining whether or not it gives rise to a knowledge or suspicion of money laundering;
  1. Ensure that the Reporting Officer/Unit has/have reasonable access to any other information which may be of assistance to the Officer/Unit and which is available to the relevant person;
  1. Require that the information contained in a report is disclosed promptly to the Anti-Money Laundering Council where the Reporting Officer/Unit knows, suspects or is made aware of any suspicious transactions; and,
  1. Maintain a register of all reports made to the Anti-Money Laundering Council, as well as all reports made by its own staff relative to suspicious transactions, whether or not such were reported to the Anti-Money Laundering Council. Said register shall contain details of the date on which the report is made, the person who makes the report and information sufficient to identify the relevant papers.
  1. COMPLIANCE

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  1. Compliance Officer/Unit. The Compliane Officer/Unit shall be tasked to advise management and the Company’s staff on the issuance and enforcement of in-house instructions to promote adherence to these Operating Rules, including personnel training, reporting of suspicious transactions, and generally, all matters relating to the prevention of money laundering.
  1. 2 . Qualifications and Responsibilities of Compliance Officer or Head of Compliance Unit. The Compliance Officer, or the Head of the Compliance Unit, shall be:
  1. a senior officer with relevant qualifications and experience to enable him to respond sufficiently well to inquiries relating to the relevant person and the conduct of its business;
  1. responsible for establishing and maintaining a manual of compliance procedures in relation to the business of the Company;
  1. responsible for ensuring compliance by the officers and employees of the Company with the provisions of the Anti-Money Laundering Act and its Implementing Rules;
  1. responsible for disseminating to the Board of Directors, officers, and all employees memorandum circulars, resolutions, instructions, and policies issued by the Anti-Money Laundering Council and the Securities and Exchange Commission in all matters relating to the prevention of money laundering;
  1. (e) act as the liaison between the Company and the Anti-Money Laundering Council in matters relating to compliance with the provisions of the Anti-Money Laundering Act and these rules;
  1. prepare and submit to the Anti-Money Laundering Council written reports on the Company’s compliance with the provisions of the Anti-Money Laundering Act, , in such form and submitted at such time as the Anti-Money Laundering Council may determine.

Although the reporting responsibility is with the Compliance Officer/Unit, the ultimate responsibility for proper supervision, reporting and compliance to the Act, as amended, and its Implementing Rules and Regulations shall rest with the Company and its Board of Directors.

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  1. TRAINING
  1. Nature of Training. The Company shall provide education and training for all its staff and personnel, including its directors and officers, to ensure that they are fully aware of their personal obligations and responsibilities in combating money laundering and to be familiar with its system for reporting and investigating suspicious matters.

The general scope of the training programs that will be adopted shall be as follows:

  1. New Staff

A general appreciation of the background to money laundering and the need to be able to identify suspicious transactions and report such transactions to the appropriate designated point within the Company. This training shall be provided to all new employees, regardless of level of seniority.

  1. Cashiers/Dealers' Representatives or Investment Representatives/Advisory Staff

Personnel who deal directly with the public are the first point of contact with potential money launderers. Their efforts are therefore vital to the Company’s reporting system for such transactions. They should be trained to identify suspicious transactions and on the procedure to be adopted when a transaction is deemed to be suspicious. "Front-line" staff should be made aware of the Company’s policy for dealing with non-regular customers particularly where large cash transactions are involved, and the need for extra vigilance in cases under suspicious circumstances.

  1. Supervisors and Managers

A higher level of instruction covering all aspects of money laundering procedures should be provided to supervisors and managers. This will include the offences and penalties arising from the Anti-Money Laundering Act, procedures relating to service of production and restraint orders, internal reporting procedures, and the requirements for verification of identity and the retention of records.

  1. Annual Refresher Training. Annual Refresher Trainings shall be scheduled to ensure that key staffs are reminded of their responsibilities and to make them aware of any changes in the laws and rules relating to money laundering, as well as the internal procedures of the Company.

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