Money laundering is defined as the process where the identity of the proceeds of crime is so disguised that it gives an impression of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firms’ knowledge or suspicion. In response to the scale and effect of money laundering, the European Union has passed Directives designed to combat money laundering and terrorism. These Directives, together with regulations, rules and industry guidance, form the cornerstone of our AML/CTF obligations and outline the offenses and penalties for failing to comply. Walahala senior management have implemented systems and procedures that meet the standards set forth by the European Union. This decision reflects the senior management’s desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
The Walahala AML Policy is designed to prevent money laundering by meeting the European standards on combating money laundering and terrorism financing, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the standards which must be complied with and includes:
Appointing a Money Laundering Reporting Officer (MLRO) who has a sufficient level of seniority and independence, and who has responsibility for oversight of compliance with the relevant legislation, regulations, rules and industry guidance. Walahala has the assigned Compliance officer who is responsible for implementation of Walahala AML policy, including but not limited to, of the listed activities.
• Establishing and maintaining a Risk-Based Approach (RBA) to the assessment and management of money laundering and terrorist financing risks faced by the firm;
• Establishing and maintaining risk-based Customer Due Diligence (CDD), identification, verification and Know Your Customer (KYC) procedures, including enhanced due diligence for customers presenting a higher risk, such as Politically Exposed Persons (PEPs);
• Establishing and maintaining risk-based systems and procedures for the monitoring of on-going customer activity;
• Establishing procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
• Maintaining appropriate records for the minimum prescribed periods;
• Providing training for and raising awareness among all relevant employees.
• Before any customer can access and benefit of Walahala services, identity of such customer has to be established.
• For Walahala to be able to establish the identity of its customer, Walahala must obtain sufficient data/documents/information from a (perspective) customer and verify such data/documents/information against independent sources. Customers that in the opinion of Walahala pose higher risk may be investigated more thoroughly which may result in requesting of additional information and taking longer term for verification of the identity of such customer. Walahala retains a right to re-establish the identity of the customer in cases where Walahala Ltd sees it fit and in relation to that, request additional data/documents/information or renew previously submitted.
• Customer’s identification information will be collected, stored, shared and protected strictly in accordance with Walahala Privacy Notice and related regulations.
• To mitigate and minimize the risks, Walahala has adopted a risk-based approach which enables to identify, assess, and understand the money laundering and terrorist financing risk to which Walahala Ltd is exposed, and take the appropriate mitigation measures in accordance with the level of risk. Risk based approach also allows to pay most of the attention to the higher risk and allocate most of the resources for mitigation of such risks.
• To get to know its customers, Walahala performs ongoing and retrospective monitoring. Monitoring performed by Walahala intends not to only to get to know the customer, but also to notice unconformities taking into comparison information submitted to Walahala by the customer or obtained by Walahala during establishment of the identity and such customer’s actual activities using Walahala services and to catch any attempts of fraudulent, illegal or unlawful activity.
• Walahala uses both manual and automated solutions to track its customers’ transactions. Walahala may use other measures on case by case basis.
• Each suspicious activity will be thoroughly investigated and, if necessary, reported to the respective authorities or other restrictive measures taken to ensure no money laundering or terrorist financing activity is performed. Walahala is entitled to request additional information/data/documents in relation to any transaction and the customer must follow the such request.
Following its AML Policy and the applicable legal acts, Walahala, when necessary, will report to the respective authorities of the activities that may be considered as money laundering and terrorist financing. Walahala will not disclose any information about such report to have been made and will not address any questions in relation to that.
Walahala is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Walahala will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.