AML (Anti-Money Laundering) Policy

Company Name: Global Internet Fortunes

1. Introduction

Global Internet Fortunes is committed to maintaining the highest standards of ethics, integrity, and compliance with applicable laws and regulations, including anti-money laundering laws. This Anti-Money Laundering (AML) policy outlines the measures and procedures implemented by Global Internet Fortunes to prevent and detect money laundering activities. This policy applies to all employees, contractors, and representatives of Global Internet Fortunes.

2. Responsibilities

2.1. Management Responsibilities

Global Internet Fortunes’ management is responsible for implementing and overseeing the AML policy. They will ensure that appropriate measures are in place to prevent money laundering activities and that employees are trained and educated on their obligations under this policy.

2.2. Employee Responsibilities

All employees, members, and representatives of Global Internet Fortunes are responsible for adhering to the AML policy. They are expected to exercise due diligence, identify suspicious activities, and report any concerns promptly to the designated AML compliance officer.

3. Customer Due Diligence (CDD)

3.1. Identification and Verification

Global Internet Fortunes will establish and maintain risk-based procedures to verify the identity of customers. This includes obtaining and verifying valid identification documents, such as government-issued IDs, passports, or other acceptable forms of identification.

3.2. Enhanced Due Diligence (EDD)

In cases where higher risks are identified, such as transactions involving politically exposed persons (PEPs) or high-risk jurisdictions, Global Internet Fortunes will apply enhanced due diligence measures. This may include gathering additional information, conducting background checks, and seeking senior management approval for the business relationship.

4. Monitoring and Reporting

4.1. Transaction Monitoring

Global Internet Fortunes will implement a robust system to monitor transactions for suspicious activities. This includes utilizing technology, such as transaction monitoring software, to identify patterns and anomalies that may indicate money laundering or terrorist financing activities.

4.2. Reporting Suspicious Activities

If an employee or a member suspects or has reasonable grounds to suspect that a transaction, customer, or activity may be related to money laundering or terrorist financing, they must promptly report it to the designated AML compliance officer. Global Internet Fortunes will maintain procedures to ensure the confidentiality and protection of those who report suspicious activities.

5. Training and Awareness

Global Internet Fortunes will provide regular training and awareness programs to all employees and members to ensure they understand their AML obligations and can recognize potential red flags. Training will cover topics such as customer due diligence, transaction monitoring, reporting obligations, and the consequences of non-compliance with the AML policy.

6. Record Keeping

Global Internet Fortunes will maintain appropriate records of customer due diligence, transaction records, and suspicious activity reports. These records will be retained in accordance with applicable laws and regulations.

7. Compliance Testing and Audit

Regular compliance testing and independent audits will be conducted to assess the effectiveness of the AML policy and procedures. Findings and recommendations from these assessments will be addressed promptly to ensure ongoing compliance.

8. Non-Retaliation

Global Internet Fortunes prohibits any form of retaliation against employees who report suspicious activities in good faith. Any reprisals or retaliation will be subject to disciplinary action.

9. Review and Updates

This AML policy will be reviewed periodically to ensure its effectiveness and compliance with changing laws and regulations. Updates will be made as necessary, and employees will be notified of any changes.

By adhering to this AML policy, Global Internet Fortunes aims to protect its reputation, maintain the integrity of its operations, and contribute to the global fight against money laundering and terrorist financing.

Date of Policy: 24/5/2024
Policy Owner: [Global Internet fortunes]