1. Policy Statement & Scope
Commitment: Formally state the firm’s commitment to prohibiting money laundering and terrorist financing.
Legal Basis: Cite compliance with Regulation (EU) 2024/1624 (AMLR) and relevant national transpositions of AMLD6.
2. Governance & Compliance Function
Compliance Manager: Appointment of a senior management member responsible for implementing the AML/CFT framework.
Compliance Officer: Designation of a senior individual for daily operations, including reporting to Financial Intelligence Units (FIUs).
Independent Audit: Provisions for an independent audit function to test internal controls.
3. Risk-Based Approach (RBA)
Business-Wide Risk Assessment (BWRA): Procedure to identify inherent risks related to customers, countries, and products.
Risk Categorization: Criteria for classifying customers as Low, Medium, or High risk (e.g., using the EU list of high-risk third countries).
4. Customer Due Diligence (CDD)
Identification & Verification: Standard procedures for natural persons and legal entities, including verifying Beneficial Ownership.
Enhanced Due Diligence (EDD): Mandatory stricter checks for Politically Exposed Persons (PEPs) and transactions over €10,000 for certain sectors.
Ongoing Monitoring: Regular review of the business relationship and transactions to ensure consistency with the customer’s risk profile.
5. Reporting & Record-Keeping
Suspicious Activity Reporting (SAR): Internal and external protocols for filing reports with national FIUs without “tipping off” the customer.
Data Retention: Policy to retain all CDD and transaction records for a minimum of five years post-relationship.
6. Training & Awareness
Employee Training: Mandatory annual training for all staff involved in AML compliance, agents, and distributors.
Competency Assessments: Regular evaluation of staff skills and integrity regarding AML/CFT duties.
Contact Us
If you have any questions about these Terms of Use, You can contact us:
By email: support@twctmt.com