Quality and Assurance Policy

1. Purpose

The purpose of this Quality and Assurance Policy is to ensure the accuracy and completeness of customer proﬁles, compliance with Anti-Money Laundering (AML) and sanctions regulations, and the continuous monitoring of payment activities. This policy outlines the processes for quality control checks and the steps to maintain the integrity of customer information, beneﬁcial ownership, and controller data for entities.

2. Scope

This policy applies to all departments and employees involved in customer onboarding, proﬁle maintenance, AML compliance, and payment processing. It encompasses all types of customer accounts managed by our company.

3. Responsibilities

Customer Service Team: Responsible for updating and verifying customer proﬁles.
Compliance Team: Conducts AML and sanctions alert reviews, re-reviews, and escalations.
Operations Team: Manages ongoing payment screening alerts and ensures real-time monitoring.
Management: Oversees the overall implementation and compliance with this policy.

4. Customer Proﬁle Accuracy

Veriﬁcation: Customer proﬁles, including risk ratings, will be veriﬁed for accuracy and completeness when customer onboarding.
Regular Updates: The customer information will be updated every three months or whenever there are changes in the customer’s situation.
Documentation: Required documents include identiﬁcation proof, address veriﬁcation, source of wealth, and any other relevant data necessary to maintain an accurate proﬁle.

5. AML and Sanctions Alerts Re-Review

Initial Review: Upon raising an AML or sanctions alert, the compliance team will conduct an immediate investigation following standard procedures.
Periodic Re-Review: Automated AML and sanctions monitoring system has been applied for real time screening. Past alerts will be re-reviewed manually semi-annually to ensure no suspicious activity was overlooked.
Escalation Procedures: Unresolved or signiﬁcant alerts will be escalated to senior compliance officers for further investigation and action.

6. Beneﬁcial Ownership and Controller Information

Entities: For corporate customers, beneficial ownership and controller information will be verified and updated annually.
Due Diligence: Enhanced due diligence will be conducted for high-risk entities, including thorough background checks and verification of ownership structures.
Record Keeping: All beneficial ownership and controller information will be recorded and stored securely in compliance with data protection regulations.

7. Ongoing Screening of Payments Alerts

Screening Tools: We utilize advanced AML and sanctions screening tools to monitor payment activities in real-time.
Monitoring: Payments are monitored continuously, with specific criteria set to trigger alerting for any suspicious transactions.
Review Process: Payment alerts will be reviewed promptly, and any issues will be addressed within 48 hours by the operations team.

8. Training and Awareness

Employee Training: Regular training programs will be conducted annually to ensure all employees understand their responsibilities under this policy.
Regular Updates: Employees will be informed of any changes to the policy or procedures through internal communications and training sessions.

9. Compliance and Auditing

External Audits: Internal audits will be conducted every three years to assess this policy.
External Consultant: External consultant will be conducted semi-annually to review the policy and identify areas for improvement.
Reporting: Any findings related to non-compliance or areas for improvement will be reported to senior management for corrective action.

10. Review and Updates

Policy Review: This policy will be reviewed annually, or more frequently if required, to ensure its effectiveness and relevance.
Approval: Any changes to the policy must be approved by the management team before implementation.