ANTI-MONEY LAUNDERING POLICY AND PROCEDURES OF FAST & RELIABLE SERVICES LIMITED

Last review date: 04 Jan 2021

Prepared by: Omar Njie

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POLICY STATEMENT

These are the Anti-Money Laundering (ALM) Policy and Procedures adopted by Fast & Reliable Services Ltd in compliance with The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Fast & Reliable Services Ltd will actively prevent and take appropriate measures to guard against our platform being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities. This document is a live document and will be updated as necessary to comply with our legal obligations.

To these ends:

• The identities of all new and existing clients will be verified to a reasonable level of certainty.
• A risk-based approach will be taken to the monitoring our customers transactions.
• Any suspicious activity will be reported, and all AML activities recorded.
• Mr. Omar Njie will act as the Money Laundering Reporting Officer (MLRO) to coordinate the AML policies and procedures of the business.
• All staffs or Agents of Fast & Reliable Services Ltd are required to acknowledge that the policy and procedures have been read and understood before representing or acting on behalf of the company.
• All Staffs or Agents of Fast and Reliable services must complete Anti-Money Laundering and Financial Crime Course.

NAME OF STAFF MEMBER	SIGNATURE	DATE
Omar Njie	Signed Electronically	04 Jan 21

ANTI-MONEY LAUNDERING PROCEDURES FOR FAST & RELIABLE SERVICES LIMITED

1. CUSTOMER DUE DILIGENCE

The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients are verified to a reasonable level of certainty. Identities will be verified either online or face-to face or by a combination of both.

The following documentation may be requested and not limited to the list below:

In person

• Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.
• An original recent utility bill, or government issued document with the same and address matching those provided by the individual.

Not in person

As in person but additionally:

• Other forms of identity confirmation, such as evidence of a long standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty.

If the business fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.

2. RISK ASSESSMENT AND ONGOING MONITORING

The business shall take a risk-based approach in monitoring the financial activities of its clients. Fast and Reliable Services Ltd has invested in www.remitanywhere.com software to ensure the following:

• To ensure that client transactions are monitored and safeguards are put in place to ensure that all transactions are verified and approved before funds can be transmitted.
• Set controls where the software will prompt for more documentations and extra information on sending large amounts of monies in accordance with Fast & reliable Services Money laundering policy.

TRANSACTION MONITORING

We have adequate controls pertaining to the transaction activity at several instances of the life cycle of a transaction. These controls include:

Client Profiling
Risk Assessment
Client Identification Controls & Validations
Transaction Aggregation
Thresholds
Government Reporting Controls & Validations
Possible Structuring Reporting
Enhanced Due Diligence Reporting

The business will actively not accept high-risk clients that are identified as follows:

• Clients with businesses that handle large amount of cash (i.e. Cash Transactions over £500 will be scrutinised and more information requested). Failure to provide the information requested may result in your account frozen or blacklisted and reported to the authorities.
• Clients sending £1000 or more will be required to provide extra information on the sources of funds and the intended use of such funds.
• Clients with larger one-off transactions, or a number of transactions carried out by the same customer within a short space of time.
• Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organised crime or drug production/distribution.
• Situations where the source of funds cannot be easily verified.
• Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
• Money sent to or received from areas known to have high levels of criminality or terrorist activity.

The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date or information held evidencing the customer’s identity are kept up to date.

The following are examples of changes in a client’s situation that may be considered suspicious:

• A sudden increase in business from an existing customer;
• Uncharacteristic transactions which are not in keeping with the customer’s known activities;
• Peaks of activity at particular locations or at particular times;
• Unfamiliar or untypical types of customer or transaction.

Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

No action need be taken if there is no cause for suspicion.

3. INTERNAL CONTROLS AND COMMUNICATION

Authorisation: All transactions must be authorised prior to the receiver Country (The Gambia) seeing the transaction. This ensures that all transactions are checked carefully in accordance with our Anti-Money Laundering procedures. Recipients are also required to provide Identity documents before any payment is to be made from the Receiving Country (the Gambia).

Personnel Control: All employees of Fast & Reliable services are required to undergo Anti-Money Laundering training prior to commencing work. Employees are also vetted and ensure that individuals with the right skillset and good character are employed.

Physical Security: All Information being digital or otherwise is securely stored and only authorised personnel have access. All Digital Information are password locked, and physical documents are stored in fireproof lockable cabinets.

Management Control: Management do ensure that control processes are always adhered to and sets the tone to the rest of the organisation. Monthly periodic checks are put in place to audit transactions at random and recommend areas for improvement where it is deemed that controls are inadequate or need improvements especially when operating in dynamic markets like this. A zero-tolerance approached to non-adherence to controls is implemented and disciplinary action is taken where applicable.

4. MONITORING AND MANAGING COMPLIANCE

The MLRO will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:

• client identity verification
• reporting suspicious transactions
• record keeping.

The MLRO will also monitor any developments in the MLR and the requirements of the MLR supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance.

ADDITIONAL MEASURES WE TAKE TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING

We may take the following additional measures to prevent money laundering, terrorist financing or other forms of financial crime.

SCANNING AGAINST THE HM TREASURY WATCH LIST

It is our policy to check each transaction against the HM Treasury watch list. Any matched names are subject to further review by the compliance officer.

5. SUSPICIOUS ACTIVITY REPORTING

A Suspicious Activity Report (SAR) will be made to the National Crime Agency (NCA) as soon as the knowledge or suspicion that criminal proceeds exist arises.

The MLRO will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.

Further details on NCA and SARS can be found at http://www.nationalcrimeagency.gov.uk

6. RECORD-KEEPING

Records of all identity checks will be maintained for up to 5 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data or information held in evidence of customer identity are kept up to date.

Copies of any SAR, together with any supporting documentation filed will be maintained for 5 years from the date of filing the SAR.

All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.

7. TRAINING

The training of staff is not applicable as the business only has one employee involved in ML compliance who is also the MLRO.

All affected employees are provided with training that explains The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, The Proceeds of Crime Act 2002 and section 18 and 21A Terrorism Act 2000, and they these affect the firm, its clients and its employees.

All affected employees are trained on their responsibilities in relation to money laundering legislation, and are aware of how to identify and deal with transactions that may involve money laundering. All staffs must complete refresher training on Anti-Money Laundering and Financial Crime at least once every 24 months.

8. REFERENCES:

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations https://www.legislation.gov.uk/uksi/2017/692/contents

Terrorism Act 2000 https://www.legislation.gov.uk/ukpga/2000/11/contents

HMRC – Money Laundering Supervision https://www.gov.uk/guidance/money-laundering-regulations-introduction

National Crime Agency http://www.nationalcrimeagency.gov.uk/crime-threats/money-laundering