The purpose of this policy is to provide guidance on the Anti-Money Laundering and Know your Client Policy which is followed by GBXMARKETS MARKETS SVG LCC (the “Company”) in order to achieve full compliance with the relevant anti-money laundering legislation.
Investment Firms are required to comply with the provisions of the new Anti-Money Laundering Law of 2007 (the “Law” for the purposes of this policy) regarding the prevention of Money Laundering and Terrorist Financing. The main purpose of the Law is to define and criminalize the laundering of proceeds generated from all serious criminal offences aiming at depriving criminals from the profits of their crimes.
In accordance with the Law, Financial Institutions are obliged to set out policies and procedures for preventing money laundering activities. Those procedures, which are implemented by the Company, as these are requested by the Law, are the following:
Internal reporting procedures to a competent person (e.g. Anti-Money Laundering Compliance Officer) appointed to receive and consider information that give rise to knowledge or suspicion that a client is engaged in money laundering activities.
Appropriate procedures of internal control, risk management, with the purpose of preventing money laundering activities. The detailed examination of every transaction that due to its nature is considered vulnerable to money laundering, and especially for complicated or unusually large transactions and transactions that are taken place without an obvious financial or legal purpose.
The provisions of the Law have been adopted by the Company, which introduces procedures
and processes that ensure compliance with the Law and the Directive of the Anti-Money Laundering Law of 2007.
The Company has adopted all requirements of the Law in relation to client identification and due diligence procedures. The client categorization, identification and due diligence are as follows:
Clients with the following criteria are classified as High risk due to the following conditions:
Any other Client determined by the Company itself to be classified as such.
Due diligence procedures are applied in the following cases:
Failure or refusal by a client to submit the requisite data and information for the verification of his/her identity and the creation of his/her economic profile, without adequate justification, constitutes elements that may lead to the creation of a suspicion that the client is involved in money laundering or terrorist financing activities. In such an event, the Company have the right to not proceed with the establishment of the business relationship .
The funding of terrorist organizations is made from both legal and illegal revenue generating activities. Criminal activities generating such proceeds include kidnappings (requiring ransom), extortion (demanding “protection” money), smuggling, thefts, robbery and narcotics trafficking. Legal fund-raising methods used by terrorist groups include:
Funds obtained from illegal sources are laundered by terrorist groups by the same methods used by criminal groups. These include cash smuggling by couriers or bulk cash shipments, structured deposits to or withdrawals from bank accounts, purchases of financial instruments, wire transfers by using “straw men”, false identities, front and shell companies as well as nominees from among their close family members, friends and associates.
Non–profit and charitable organizations are also used by terrorist groups as a means of raising funds and/or serving as cover for transferring funds in support of terrorist acts. The potential misuse of non-profit and charitable organizations can be made in the following ways:
Upon the initial client meeting the necessary due diligence procedures, as described above, are applied to ensure all Know Your Client (KYC) policies are adhered to, all documents necessary for proceeding with KYC procedure are provided and the Company may accept the client and proceed to the account opening. Subsequently the client completes the account opening forms indicating all required information.
Prior to accepting new clients and allowing them to trade with the Company, the following documents shall be obtained for the verification of clients’ identity:
A different identification procedure is followed for corporate clients interested in opening an account with the Company. The documentation for identification and documentation purposed that needs to be obtained by the corporate clients is presented below:
Applicable to Corporate Accounts/Legal Entities:
