DATACLUB S.A. ANTI MONEY-LAUNDERING (AML) POLICY

Policy

It is the policy of DATACLUB S.A. and its affiliates, (hereinafter “DATACLUB S.A.”) to prohibit and actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. DATACLUB S.A. is committed to AML compliance in accordance with applicable laws of jurisdictions where DATACLUB S.A. offers corporate and legal services. DATACLUB S.A. requires its officers, employees and affiliates to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the purposes of the Policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

Generally, money laundering occurs in three stages. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

Each employee of DATACLUB S.A., whose duties are associated with the provision of products and services of DATACLUB S.A. and who directly or indirectly deals with the clientele of DATACLUB S.A., is expected to know the requirements of the applicable laws and regulations which affect his or her job responsibilities, and it shall be the affirmative duty of such employee to carry out these responsibilities at all times in a manner that complies with the requirements of the relevant laws and regulations.

The laws and regulations include, but not limited to: “Customer Due Diligence for Banks” (2001) and “General Guide to Account Opening and Customer Identification” (2003) of Basel Committee of banking Supervision, Forty + nine Recommendations for Money Laundering of FATF, USA Patriot Act (2001), Prevention and Suppression of Money Laundering Activities Law of (1996).

To ensure that this general policy is carried out, management of DATACLUB S.A. has established and maintains an ongoing program for the purpose of assuring compliance with the relevant laws and regulations and the prevention of money laundering. This program seeks to coordinate the specific regulatory requirements throughout the group within a consolidated framework in order to effectively manage the group’s risk of exposure to money laundering and terrorist financing across all business units, functions, and legal entities.

Each of the affiliates of DATACLUB S.A. is required to comply with all aspects of the group’s policy as well as their own AML policies which specifically consider the local AML laws and requirements to which they are subject. Failure by the group and its affiliates to comply with the all applicable local AML laws and regulations could result in severe regulatory sanctions, possible fines and criminal penalties and damage to the group’s business reputation.

Risk Assessment

An assessment of the risk of exposure to money laundering issues across all customer relationships shall be completed using the DATACLUB S.A. standardized risk rating model. The risk rating model shall be approved by the Board of Directors on an annual basis.

Suspicious Activities

There are signs of suspicious ctivity that suggest money laundering. These are commonly referred to as “red flags.” If a red flag is detected, additional due diligence will be performed before accepting client’s requests or providing services.

Examples of red flags are:

  • The customer exhibits unusual concern regarding the AML policies, particularly with respect to his or her identity, type of business and assets, or is reluctant or refuses to reveal any information concerning business activities, or furnishes unusual or suspect identification or business documents.
  • The customer wishes to engage in transactions that lack business sense or apparent investment strategy, or are inconsistent with the customer’s stated business strategy.
  • The information provided by the customer that identifies a legitimate source for funds is false, misleading, or substantially incorrect.
  • Upon request, the customer refuses to identify or fails to indicate any legitimate source for his or her funds and other assets.
  • The customer (or a person publicly associated with the customer) has a questionable background or is the subject of news reports indicating possible criminal, civil, or regulatory violations.
  • The customer exhibits a lack of concern regarding risks, commissions, or other transaction costs.
  • The customer appears to be acting as an agent for an undisclosed principal, but declines or is reluctant, without legitimate commercial reasons, to provide information or is otherwise evasive regarding that person or entity.
  • The customer has difficulty describing the nature of his or her business or lacks general knowledge of his or her industry.
  • The customer attempts to make frequent or large deposits of currency, insists on dealing only in cash equivalents.
  • For no apparent reason, the customer has multiple accounts under a single name or multiple names, with a large number of inter-account or third-party transfers.
  • The customer is from, or has accounts in, a country identified as a non-cooperative country or territory by the Financial Action Task Force.
  • The customer’s account has unexplained or sudden extensive wire activity, especially in accounts that had little or no previous activity.
  • The customer’s account shows numerous currency or cashiers check transactions aggregating to significant sums.
  • The customer’s account has a large number of wire transfers to unrelated third parties inconsistent with the customer’s legitimate business purpose.
  • The customer’s account has wire transfers that have no apparent business purpose to or from a country identified as money laundering risk or a bank secrecy haven.
  • The customer’s account indicates large or frequent wire transfers, immediately withdrawn by check or debit card without any apparent business purpose.
  • The customer makes a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.
  • The customer makes a funds deposit for the purpose of purchasing a long-term investment followed shortly thereafter by a request to liquidate the position and transfer of the proceeds out of the account.
  • The customer engages in excessive journal entries between unrelated accounts without any apparent business purpose.
  • The customer requests that a transaction be processed in such a manner to avoid the firm’s normal documentation requirements.
  • The customer, for no apparent reason or in conjunction with other red flags, engages in transactions involving certain types of securities, such as penny stocks, bearer bonds, which although legitimate, have been used in connection with fraudulent schemes and money laundering activity. (Such transactions may warrant further due diligence to ensure the legitimacy of the customer’s activity.)

Customer Identification

DATACLUB S.A. will document and maintain written customer identification procedures (“CIP”) that will enable to form a reasonable belief that DATACLUB S.A. knows the true identity of each customer. If the DATACLUB S.A. is not able to verify the identity of a customer within a reasonable period of time after services or account opening request, that services shall be suspended and account will be closed. Such an account and services will be subject to increased due diligence until such time as the customer’s identity has been verified or the account has been closed and services suspended.

CIP for Natural Persons

For natural persons the following information should be obtained, where applicable:

  • Legal name and any other names used (such as maiden name).
  • Correct permanent address (the full address should be obtained. a Post Office box number is not sufficient).
  • Telephone number, fax number, and e-mail address.
  • Date and place of birth.
  • Nationality.
  • Occupation, public position held and/or name of employer.
  • An official personal identification number or other unique identifier contained in an unexpired official document (e.g. – passport, identification card, residence permit, social security records, driving license) that bears a photograph of the customer.
  • Source of wealth (where appropriate).

DATACLUB S.A. shall verify this information by at least one of the following methods:

  • Confirming the date of birth from an official document (e.g. birth certificate, passport, identity card, social security records).
  • Confirming the permanent address (e.g. utility bill, tax assessment, bank statement, a letter from a public authority).
  • Contacting the customer by telephone, by letter or by e-mail to confirm the information supplied after an account has been opened or other services provided (e.g. a disconnected phone, returned mail, or incorrect e-mail address should warrant further investigation).
  • Confirming the validity of the official documentation provided through certification by an authorized person (e.g. embassy official, notary public).

CIP for Institutions

The underlying principles of customer identification for natural persons have equal application to customer identification for all institutions. Where in the following the identification and verification of natural persons is involved, the foregoing guidance in respect of such persons shall have equal application. The term institution includes any entity that is not a natural person.

For corporate entities (i.e. corporations and partnerships), the following information should be obtained:

  • Name of institution.
  • Principal place of institution’s business operations.
  • Mailing address of institution.
  • Contact telephone and fax numbers.
  • Some form of official identification number, if available (e.g. tax identification number).
  • The original or certified copy of the Certificate of Incorporation and Memorandum and Articles of Association.
  • Nature and purpose of business and its legitimacy.

This information should be verified by at least one of the following methods:

  • For established corporate entities – reviewing a copy of the latest report and accounts (audited, if available).
  • Conducting an enquiry by a business information service, or an undertaking from a reputable and known firm of lawyers or accountants confirming the documents submitted.
  • Undertaking a company search and/or other commercial enquiries to see that the institution has not been, or is not in the process of being, dissolved, struck off, wound up or terminated.
  • Utilizing an independent information verification process, such as by accessing public and private databases.
  • Obtaining prior bank references.
  • Visiting the corporate entity, where practical.
  • Contacting the corporate entity by telephone, mail or e-mail.

Recordkeeping

All identification documentation and services records shall be kept for the minimum period of time required by local law.

Security Checks

Previous to accepting a “New Registration” the following security checks are to be undertaken on the individual or organization in question.
  • World CHECK/OFAC Analyser

    Individuals/organizations names are run through the world check/OFAC database for any matches/ssociation to known heightenedrisk individuals and entities for potential risk relating to money laundering, terrorist financing and over 20 other types of risk.

    • No Match

      If no match is found for the individual or organization, a report is saved and recorded.

    • Match

      Profiles of individuals or organizations are categorized according to their level of risk. (See Annex 1)

    In the event that an individual or organization is found to be a match and categorized as HIGH RISK, the following procedures are put in place:

    • Decline account registration and save profile on record.
    • Update World-Check/OFAC database with any relevant information not listed on individual/organization profile.
    • Report to the money laundering reporting officer (“MLRO”).
    • Report any suspicious activity to the relevant authorities.

    In the event that an individual or organization is found to be a match and categorized as LOW RISK, the following procedures should be undertaken:

    • Based on the category, the profile should be recorded and the application processed, and the client rated accordingly in regards to internal client risk rating.
    • If it is felt that more information is required for the client in question, a Compliance Check Questionnaire should be forwarded to the client for completion, (See Annex 2) and further searches carried out for additional information.
    • Provided all is in order on receipt of the completed questionnaire, it should be saved and recorded to the clients file.

    In the case that the client appears to be of high profile or risk, further detail and information will be required in regards to the relevant question giving this assumption, and further security checks carried out by GFSC.

Due Diligense Documentation

In verifying the personal information supplied by the customer, the financial services business will do so by holding the following documentation:
  • Identification

    A certified copy of an official personal identification number or other unique identifier contained in an unexpired official document that bears a photograph of the client, for example:

    • Passport
    • National Identification Card
    • National Residence Permit
    • Driving License
  • Proof Of Residence

    Individual:

    An original or certified copy of a document carrying the name and residential address of the individual in mention, which is no more than three (3) months old.

    Minor/Student:

    An original or certified copy of a document carrying the parental home address as the principal residence with an accompanying letter/e-mail from the parent and certified copy of parent’s identification.

    Couples:

    An original or certified copy of a document carrying the name and residential address of either individual, provided a copy of the marriage certificate is supplied.

    Acceptable Documents:

    • Utility bill
    • Bank /credit card statement
    • Letter of employment (on official company letterhead, stating employment period and residential address)
    • Lawyer’s confirmation of property purchase, or legal document recognizing title to property.
    • A personal visit to the residential address (by Director or Manager)
    • Copy of lease agreement
    • House insurance
    • Sworn affidavit
  • Corporate Documentation

    In identifying and verifying the individuals involved and the organization, the following documents must be submitted:

    • Certificate of incorporation/constitution
    • Directors list or CR14 (company lodgment)
    • Memorandum, and articles of association/incorporation

    Company Directors

    Requirements are as those of an individual. See Section 3.a and 3.b.
  • Document Certification

    The following wording needs to be included on certified copies.

    • Identification Documents:

      “ Having seen the original document and the bearer at the same time, I can certify that this is a true copy and reasonable likeness.”

    • Proof of Residence Documents:

      “ Having seen the original document, I can certify that this is a true copy.”

    The following is a list of persons acceptable to certify due diligence documents:

    • Member of the judiciary, a senior civil servant, or a serving police or customs officer.
    • Officer of an Embassy, consulate or high commission of the Country or territory of the issue of documentary evidence of Identity.
    • Lawyer or notary public who is a member of a recognized professional body.
    • Actuary who is a member of a recognized professional body
    • Accountant who is a member of a recognized professional Body.
    • Member of the Institute of Chartered Secretaries and Administrators; and
    • Director or officer of a Financial Services Business.

    Certifiers should include the following information on all copy documents:

    • Full name of Certifier:
    • Company:
    • Position:
    • Signed:
    • Date:

    For further information refer to part 4(e) of the Manual on Countering Financial Crime and Terrorist Financing

  • Documents Receipt

    All documentation received must be either in original form or certified copies.

    Documentation received via e-mail must be clear scanned certified copies of the original documents.

    Documentation submitted at an agent’s offices must be either the original documentation submitted in person by the account holder or the original certified copies.

    Original documentation brought in by the account holder will be scanned, copied and verified in person by a Compliance Officer on behalf of EBC and further certified by a Commissioner of Oaths consulting on behalf of EBC.

  • Documentation Verification

    Identification numbers and proof of residence documentation showing residential address are used to verify the personal details submitted in the application form.

    • Identification

      Identification documents in the format of passports and national ID’s are placed through the World Check Passport Check System for verification.

      Passport and national ID’s are checked for validity. Passports that expire within the next two months are not accepted and an alternate form of identification is required.

      Individuals obtaining false documentation are reported to the relevant authorities and the relevant High Commission.

      Viewing of the individual and the original or certified copy of the identification document at the same time are given visual verification.

    • Proof of Residence

      Documents provided as proof of residence are cross-referenced against the personal information provided in the registration form. Utility bills provided as proof of residence that are older than three months are not accepted.

      Employment letters provided as proof of residence should be on an official company letterhead showing company address and contact details and be signed and dated by a company manager/director.

Transfers

  • Outgoing Transfers

    • Required Documentation

      All Outgoing Wire Transfers require the following information for verification and security reasons:

      • Purpose of payment
      • Supporting documentation (clearly confirming the purpose of payment and the end beneficiary)
      • Information on the receiving party
      • Confirmation that the client did indeed request the transfer submitted.
    • Security Checks

      The beneficiary bank and the beneficiary account name are run through the world check/OFAC database for any matches/association to known heightened-risk individuals and entities for potential risk relating to money laundering or terrorist financing.

    • Transaction Authorization

      Documentation received should be verified by confirming:

      • Value
      • The suppliers’ invoice corresponds to the beneficiary account name
      • The customers name corresponds to the client’s name and the document is a recent up to date invoice giving physical address and contact details on official company letterhead
      • All documentation should be submitted in un-editable format, being PDF/JPEG

      For further verification on the authenticity on documentation, the administrator processing the transaction should contact the supplier of the invoice directly for confirmation of the transaction in question as being a valid business deal.

      With the documentation supplied being verified and confirmed legitimate, the Outgoing Wire Transfer can be executed.

    • Suspicious Transactions

      Detecting a suspicious transaction is based on the following transaction situations:

      • Out of the ordinary transaction based on the clients’ transaction history
      • If the beneficiary or originating account name is found to be associated to any form of illegal financing or financial fraud during security checks
      • If the value of transfer does not logically match with the invoice submitted or the purpose of the transfer
      • If the transfer is destined for a black listed country (NCCT)
      • If the transfer is allowed for urgency and the client does not submit the required documentation in the requested time frame

      If it is felt that a transaction is deemed suspicious, it is required that the processing of the transaction be discontinued and reported.

    • Declined Transactions

      Outgoing Wire Transfers should be declined in any one of the following circumstances:

      • Insufficient documentation
      • Beneficiary account name is a listed individual/corporate
      • Beneficiary account held in a black listed country (NCCT)

      Transactions declined due to the beneficiary account name being listed must be reported to the MLRO for further investigation. Where a transaction has been declined on the grounds of the beneficiary account name being listed, it is permitted that the administrator processing the transaction refrain from informing the client of the reason of the decline due to regulations that prevent the Financial Institute of “Tipping Off” the client in question. It is advised that the administrator inform the client of the decline for reasons due to “system errors” whilst the transaction is being further investigated.

  • Incoming Transfer

    • Required Documentation

      All Incoming Wire Transfers require the following information for verification and security reasons:

      • Source of funds
      • Supporting documentation (clearly confirming the purpose of payment and the remitting party)
      • Information on the remitting party
    • Security Checks

      The remitting bank and the remitting account name are run through the world check/OFAC database for any matches/association to known heightened-risk individuals and entities for potential risk relating to money laundering or terrorist financing.

    • Transaction Authorization

      Documentation received should be verified by confirming:

      • Value amount
      • Customer name corresponds to the remitting account name and vice versa for the client receiving the funds
      • Dated and submitted on official company letterhead
      • All documentation should be submitted in un-editable format, being PDF/JPEG

      For further verification on the authenticity on documentation / information submitted, the administrator processing the transaction should contact the remitting party directly for confirmation of the transaction in question as being a valid business deal. With the documentation supplied being verified and confirmed legitimate, the Incoming Wire Transfer can be executed.

    • Suspicious Transactions

      A suspicion may be based upon a transaction or activity, which is inconsistent with a customer’s known legitimate business, activities or lifestyle or with the normal business for that type of product/service.

      Detecting a suspicious transaction can be based on the following transaction situations:

      • Out of the ordinary transaction based on the Clients transaction history
      • If the remitting account name is found to be associated to any form of illegal financing or financial fraud during World – Check/OFAC security checks
      • If the value of transfer does not logically match with the invoice submitted or the purpose of the transfer
      • If the transfer is destined for a black listed country (NCCT)
      • If the transfer is allowed for urgency and the client does not submit the required documentation in the requested time frame

      If it is felt that a transaction is deemed suspicious, it is required that the processing of the transaction be discontinued reported to the Money Laundering Reporting Officer (“MLRO”) via a completed Internal Report Form.

    • Declined Transactions

      Incoming Wire Transfers should be declined in any one of the following circumstances:

      • Insufficient documentation
      • Remitting account name is a listed individual/corporate
      • Remitting account held in a Black Listed Country (NCCT)
      • Unable to prove source of funds
      • Value exceeds Individuals means and resources

      Transactions declined due to the remitting account name being listed must be reported to the MLRO for further investigation. Where a transaction has been declined on the grounds of the remitting account name being listed, it is permitted that the administrator processing the transaction refrain from informing the client of the reason of the decline due to regulations that prevent the financial institute of “Tipping Off” the client in question. It is advised that the administrator inform the client of the decline for reasons due to “system errors” whilst the transaction is being further investigated.

Reporting

A suspicion may be based upon a transaction or activity, which is inconsistent with a customer’s known legitimate business, activities or lifestyle or with the normal business for that type of product/service.

Recognition of a suspicious transaction or activity is for the financial services business to know enough about the business relationship to recognize that a transaction or activity is unusual. Such knowledge would arise from complying with the monitoring and ongoing customer due diligence requirements. Suspicion need not only be based on transactions or activities within the business relationship, but also on information from other sources, including media, intermediaries, or the customer himself.

Where, during the CDD (“Customer Due Diligence”) process, a financial services business knows or suspects that someone is engaged in money laundering or terrorist financing a disclosure is made to the FIS (“Financial Intelligence Services”) by the MLRO.

It is obliged that each suspicion is reported to the appointed MLRO or in his absence a Nominated Officer, regardless of the amount involved in the form of an Internal Report Form. (See Annex 3) It is then upon the MLRO/Nominated Officer to promptly investigate and determine whether there is reasonable grounds for knowing or suspecting that the reported person(s) is/are engaged in money laundering or terrorist financing.

Where the MLRO has determined that an internal suspicion report does result in there being such knowledge or reasonable grounds for suspicion of money laundering or terrorist financing, the report is disclosed to the FIS.

Once a disclosure has been made to the FIS, the MLRO immediately informs the FIS where subsequent, relevant information or documentation is received.

Where the MLRO makes the decision not to make a disclosure to the FIS, the reasons for the decision not to disclose are documented and saved to the said persons file.

All administrators and officers should appreciate and understand the significance of reporting a suspicion. It is a criminal offence for anyone employed by a financial services business to fail to report where they have knowledge, suspicion or reasonable grounds for knowledge or suspicion that another person is laundering the proceeds of any criminal conduct or is carrying out terrorist financing.

Internal Procedures

  • Documenting

    • Transactions

      In the instance of a transaction being processed on behalf of or with a client, it is necessary for the transaction to be recorded. This is to ensure that in every case sufficient information is recorded to enable the reconstruction of individual transactions so as to provide, if necessary, evidence for prosecution of criminal activity.

    • Client Request

      • Written

        Written requests submitted via email, skype or other forms of online communication must be recorded and stored to the client’s folder.

        These requests should give the following information:

        • Account holders’ account details by which it can be identified, being Security Key
        • The currency and amount of transaction requested
        • Details of the counterparty, including account details
        • The nature of the transaction
        • The date of the transaction to be effected
      • Telecommunication

        Requests submitted via telephone from a client or authorized operator must be recorded via the completion of an internal memo (See Annex 8), by the receiving administrator, giving the following information:

        • Account holders account details by which it can be identified, being Security Key
        • The currency and amount of transaction requested
        • Details of the counterparty, including account details
        • The nature of the transaction
        • The date of the transaction to be effected

        Requests submitted via telecommunication require the authenticity of the caller, by the client divulging the security key of the account in question.

        EBC reserves the right to audio-record telephone conversations with customers. Such audio recording shall be considered sufficient proof of the issue of the instructions given by the customer and serve as legal evidence.

        When using any means of remote communication, other than the client personally appearing at an EBC office, the client shall undertake all risks pertaining thereto. Upon execution of the client’s orders, EBC shall NOT be liable for any costs, errors, misinterpretations, etc, as a result of the distortion of the electronically transmitted information in the order (by email, fax, telephone, internet, etc) or due to other reasons beyond EBC’s control.

  • Data Storage

    The storage of customer due diligence (“CDD”), transaction documents, wire transfer records, internal and external suspicion reports and compliance monitoring reports are retained and stored electronically via an online storage facility.

    Each client has a folder created under their username on the opening of their EBC account. All KYC documentation and security check reports are saved in a sub folder for compliance documentation. Documentation in regards to payment transactions is stored in a further sub folder for payments & reports.

    Documentation can be retrieved from the online storage facility as and when required by the EBCG administrators and authorized users, via login details requiring a password for access to the data.

  • Client Rating

    • Client Activity Monitoring

      A financial services business is required to monitor business relationships and to apply scrutiny of unusual, complex or high-risk transactions or activity so that money laundering or terrorist financing may be identified or prevented.

      An unusual transaction or activity may be in a form that is inconsistent with the expected pattern of activity within a particular business relationship, or with the normal business activities for the type of product or service offered. This may indicate money laundering, terrorist financing activity or fraudulent activity, where the transaction or activity has no apparent economic or visible lawful purpose.

      Monitoring of clients transactions and activity is carried out on a riskbased method, with high risk clients being subjected to additional and more frequent screening and observation.

      Transaction and activity monitoring must be undertaken throughout the course of the relationship held with the client to ensure that the transactions and activity being conducted are consistent with the clients KYC, their business, source of funds and source of wealth. The monitoring of complex, unusual and large transactions or unusual patterns of transactions must be examined and recorded in writing. These examinations are based on the background and purpose of such transactions.

    • Customer Due Diligence

      To maintain KYC on all clients, it is required that ongoing CDD is conducted to ensure that any changes or developments are detected, recorded and the relationship with the client monitored. The level of risk the client holds determines the degree of ongoing CDD measures.

      It is not obligatory to re-verify or obtain current documentation unless an assessment has been made that the identification data held is not adequate for the assessed level of risk of the client.

    • Transaction Activity

      Client transactions being incoming or outgoing transfers are frequently monitored for any inconsistencies in the values and number of transfers being received and sent.

      The number and value of transactions of clients determines the level of risk associated, and based on the level of risk given, subsequently determines the frequency of observation and monitoring of the Client’s activities.

      Where there are abnormal transactions, the transaction history and overall activity of the client will be examined for any traces of fraudulent activity, money laundering or terrorist financing and the risk level re - assessed based on these findings.

Glossary

Account Activity

The provision of an estimate of the total flow of funs in and out of an account together with an estimate of the expected maximum account turnover.

Beneficial Owner

The natural person who ultimately owns or controls the customer, and a person on whose behalf the business relationship or occasional transaction is to be or is being conducted and, in the case of a trust or other legal arrangements, this shall mean any beneficiary in whom an interest has vested, and any other person who appears likely to benefit from that trust or other legal arrangement.

Business risk assessment

An assessment which documents the exposure of a business to money laundering and terrorist financing risks and vulnerabilities taking into account its size, nature and complexity and its customers, products and services and the ways in which it provides those services.

Customer

A person or legal arrangement who is seeking to establish or has established, a business relationship with a financial service business, or to carry out or has carried out, an occasional transaction with a financial services business. Except that where such a person or legal arrangement is an introducer, the customer is the person or legal arrangement on whose behalf the introducer is seeking to establish or has established the business relationship.

Customer Due Diligence (CDD)

The steps which a financial services business is required to carry out in order to identify and verify the identity of the parties to a relationship and to obtain information on the purpose and intended nature of each business relationship and occasional transaction.

Customer Due Diligence Information

Identification data and any account files and correspondence relating to the business relationship or occasional transactions.

FIS

Police Officers and Customs Officers who are members of the Financial Intelligence Service.

Funds

Assets of every kind, whether corporeal or incorporeal, tangible or intangible, moveable or immovable and legal documents or instruments evidencing title to, or interest in, such assets.

Funds Transfer

A transaction carried out on behalf of an originator person (both natural and legal) through a financial institution by electronic means with a view to making an amount of money available to a beneficiary person at another financial institution. The originator and the beneficiary may be the same person.

Identification Data

Data, documents or information, in any form whatsoever, which is from a reliable and independent source.

Politically Exposed Person(s) (PEP)

Individuals who are or have been entrusted with prominent public functions in a country or territory other than Guernsey, for example. Heads of State or of a government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. Business relationships with family members or close associates of PEPs involve reputational risks similar to those with PEPs themselves. The definition is not intended to cover middle ranking or more junior individuals.

Transactions

In the general context of the Handbook, the reference to transactions should be understood to include occasional transactions, any customer facing functions, or the handling of business relationships.

Transaction Document

A document, which is a record of a transaction, carried out by a financial services business with a customer or an introducer.

Wire Transfer

Any transaction carried out on behalf of an originator person (both natural and legal) through a financial services business by electronic means with a view to making an amount of money available to a beneficiary person at another financial services business. The originator and the beneficiary may be the same person.

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