TBML / AML Policy

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Algorithm Tech Solutions Ltd

Trade-Based Money Laundering (TBML), Anti-Money Laundering (AML), and Sanctions Proliferation Policy

Introduction:

Algorithm Tech Solutions Ltd, based in London, is committed to upholding the highest standards of ethical conduct and complying with all relevant laws and regulations related to Trade-Based Money Laundering (TBML), Anti-Money Laundering (AML), and sanctions proliferation. This policy outlines our approach to preventing, detecting, and responding to TBML, AML, and sanctions proliferation risks.

1. Scope and Purpose:

This policy applies to all employees, officers, directors, contractors, consultants, and any other individuals or entities associated with Algorithm Tech Solutions Ltd. The purpose is to ensure compliance with TBML, AML, and sanctions laws, prevent the company from being used for money laundering or terrorism financing, and protect the company’s reputation and integrity.

2. Definitions:

"Money Laundering": The process of making illegally-gained proceeds appear legal.

"Trade-Based Money Laundering (TBML)": The process of disguising the proceeds of crime and moving value through trade transactions to legitimise their illicit origins.

"Sanctions": Penalties or other measures imposed by governments or international bodies to restrict trade and financial transactions with specific countries, entities, or individuals.

3. Responsibilities:

Board of Directors: Oversee the implementation and effectiveness of this policy.

Compliance Officer: Responsible for developing, implementing, and monitoring the TBML, AML, and sanctions proliferation program.

Employees: Required to comply with this policy, report suspicious activities, and attend training sessions.

4. TBML/AML Program:

4.1. Risk Assessment:

- Conduct regular risk assessments to identify and mitigate potential TBML/AML risks.

- Evaluate the company’s exposure to risks related to customers, products, services, and geographic locations.

4.2. Customer Due Diligence (CDD):

- Perform CDD measures, including verifying the identity of customers and understanding the nature of their business.

- Conduct enhanced due diligence (EDD) for high-risk customers and transactions.

4.3. Record Keeping:

- Maintain accurate records of all transactions and CDD information for at least five years.

- Ensure records are readily available for inspection by relevant authorities.

4.4. Monitoring and Reporting:

- Implement transaction monitoring systems to detect suspicious activities.

- Report any suspicious transactions or activities to the relevant authorities in a timely manner.

4.5. Training and Awareness:

- Provide regular training to employees on TBML, AML, and sanctions proliferation regulations and red flags.

- Ensure employees are aware of their responsibilities and the importance of compliance.

5. Sanctions Compliance:

5.1. Sanctions Screening:

- Screen all customers, transactions, and business partners against relevant sanctions lists.

- Ensure that no transactions are conducted with individuals, entities, or countries subject to sanctions.

5.2. Sanctions Monitoring:

- Continuously monitor and update sanctions lists to ensure compliance.

- Implement systems to automatically flag and block transactions involving sanctioned parties.

5.3. Reporting and Escalation:

- Report any sanctions violations or potential violations to the relevant authorities immediately.

- Escalate any concerns related to sanctions compliance to senior management and the board of directors.

6. Internal Controls and Audit:

6.1. Internal Controls:

- Develop and implement robust internal controls to mitigate TBML, AML, and sanctions proliferation risks.

- Regularly review and update controls to address emerging threats and regulatory changes.

6.2. Independent Audit:

- Conduct independent audits of the TBML, AML, and sanctions compliance program to ensure effectiveness.

- Address any findings or recommendations from audits promptly.

7. Reporting Mechanisms:

7.1. Whistleblower Policy:

- Establish a whistleblower policy to encourage employees to report any suspicious activities or non-compliance confidentially.

- Protect whistleblowers from retaliation.

7.2. Reporting to Authorities:

- Report any suspicious activities, transactions, or sanctions violations to the relevant authorities as required by law.

8. Review and Update:

- Regularly review and update this policy to ensure it remains effective and compliant with current laws and regulations.

- Communicate any changes to all employees and relevant stakeholders promptly.

Algorithm Tech Solutions Ltd is committed to maintaining a strong TBML, AML, and sanctions compliance program. By adhering to this policy, we aim to prevent illicit activities, protect our reputation, and ensure compliance with all relevant laws and regulations.