AML - CTF Policy | One Pacific Trust

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ANTI-MONEY LAUNDERING AND COUNTER FINANCING TERRORISM POLICY

I. INTRODUCTION

One Pacific Trust Limited is a Hong Kong-based company providing professional trust products and services, assisting clients in asset protection and long-term financial planning, maintain and comply with Hong Kong Company Registry as well as other related authority. One Pacific Trust Limited committed to the highest standards in effort to comply with the applicable Anti Money Laundering and Counter Financing Terrorism (AML-CFT) standards. The Policy provides an introduction to anti money laundering and counter financing terrorism regulation.

The Management (BOD) and all employees are required to adhere to the standards to protect One Pacific Trust Limited and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.

Government has enacted laws and rules designed to implement the anti-money laundering and counter financing terrorism. The goal of these laws is to detect and prevent money laundering and potential terrorist financing. One Pacific Trust Limited will adhere to applicable laws and regulations in Singapore.

One Pacific Trust Limited will verify its AML – CFT framework, goals and strategies on a periodical basis and maintain an effective program for the One Pacific Trust Limited’s business that reflects the best practices for financial institutions in general.

II. STRUCTURE AND POLICY

One Pacific Trust Limited has an active Supervisory Board under Compliance Officer, and the implementation of AML – CFT Program handled by AML – CFT Officer and all the team members (“MLRO”) which has been appointed by the Management. The MLRO is responsible for adherence to the applicable AML – CFT Program derived from the AML-CTF procedure.

One Pacific Trust Limited has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML – CFT regulations.

The scope of this policy covers all aspects of the Implementation of Anti Money Laundering and Counter-Financing Terrorism Prevention Program, namely:

  1. Active supervision of the Board of Directors
  2. Policies and Procedures;
  3. Internal Control;
  4. Information Management System; and
  5. Human Resources and Training

III. CUSTOMER DUE DILIGENCE

One Pacific Trust Limited has implemented know your customer (KYC) procedure to assure all kinds of customers are subject to identification and verification process. The KYC has been implemented in all branches and business units. The goals are One Pacific Trust Limited has sufficient information and data about the customers profile, whom they deal with, and also the Ultimate Beneficial Owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and customers from high risk businesses or countries, name screening, and the ongoing monitoring and updating data of all existing customers.

One Pacific Trust Limited shall refuse to support or has to close an existing clients, if the following:

  • Cannot fix a reasonable belief that it knows the true identity of the customer and/or UBOs and/or the nature of business concerning the identification of the customers are not met;
  • Known and/or suspected the utilization of fake documents;
  • Assets that are known or suspected to be the proceeds of criminal activity;
  • Enter into business relationships with individuals or entities known or suspected to be a terrorist or a criminal organization or listed on sanction lists;
  • Maintain anonymous accounts or accounts operate for shell banks.

IV. REGULATORY REPORTING

One Pacific Trust Limited has an obligation to report cash transactions with a certain amount based on relevant regulation, suspicious transaction/activity, and international fund transfer. Suspicious transactions must be handled and escalated with approval of the Compliance Officer prior reporting to the regulator.

V. AML - CFT ENTITY RISK ASSESSMENT

The AML-CFT Entity Risk Assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML-CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of Terrorism Financing based on customer, country or geographical factors, products, services, transactions or distribution channels (delivery channels).

VI.SANCTIONS COMPLIANCE

Sanctions Compliance Implementation is important in One Pacific Trust Limited activities. One Pacific Trust Limited is obligated to establish restrictions and controls on the movement of goods, services, and customers' funds that were transacted through the products and services that were provided by One Pacific Trust Limited. Sanctions Compliance implementation goal is to keep One Pacific Trust Limited from compliance risk, operational risk and reputational risk exposure. ONE IBC implements AML-CFT Sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation is based on One Pacific Trust Limited and Sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.

VII. RECORD RETENTION

One Pacific Trust Limited has to record all data and or information regarding customers documents, client’s companies and/or its financial transactions (if any). One Pacific Trust Limited maintains customer documentation for a minimum of 5 (five) years, notwithstanding longer retention as required. One Pacific Trust Limited will provide information and/or documents to competent authorities as ordered by laws and regulations, when required.

VIII. TRAINING

One Pacific Trust Limited has implemented AML – CFT training program for all staff. ONE IBC 's training program is tailored to the operations and business unit to assure all staff are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML – CFT Program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.

IX. INTERNAL CONTROL

One Pacific Trust Limited has an effective internal control system. One Pacific Trust Limited 's AML – CFT Program is subject to independent control by Internal Audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML – CFT Program.

This Policy is an integral part of One Pacific Trust Limited’s Anti-Money Laundering and Counter Financing Terrorism Procedure.