This Policy defines the principles and procedures adopted by IVM to prevent, detect and report Money Laundering (ML) and Terrorist Financing (TF) activities in compliance with applicable laws and FATF standards.
This Policy applies to all directors, officers, employees, agents, subsidiaries and business partners acting on behalf of IVM.
The Board of Directors is responsible for approving this Policy. Senior Management ensures effective implementation.
IVM applies a risk-based approach to identify, assess and mitigate ML/TF risks related to customers, jurisdictions, products and services.
All customers must be properly identified, beneficial ownership verified, source of funds documented and assigned a risk rating prior to onboarding.
High-risk customers including PEPs, offshore entities and high-risk jurisdictions require enhanced verification and senior management approval.
Transactions are monitored using automated and manual controls to detect unusual, complex or suspicious activities.
Employees must immediately report suspicious activity to the Compliance Officer. The Compliance Officer shall report to the Financial Intelligence Unit where required.
All customers are screened against international sanctions and watch lists. Prohibited parties are denied services.
Customer identification and transaction records are retained for a minimum of ten (10) years.
All staff must complete mandatory annual AML/CTF training.
This Policy is reviewed annually and audited periodically.
Violations of this Policy may result in disciplinary actions, including termination and legal proceedings.
Approved by the Board of Directors of IVM.
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