Financial crime

We are committed to complying with all relevant legislation and regulation across the jurisdictions in which we operate. Accordingly, we have developed a policy approach of constructive engagement and cooperation with all authorities charged with anti-financial crime responsibilities and our policy includes structures, processes and procedures which are designed to prevent and detect financial crime. We ensure that our approaches are in line with regulatory requirements and engage with peers across the industry and adhere to best practices as appropriate.

Risk Assessment

We adopt a risk-based approach to our business so we can best focus our resources in the areas where they are most needed, in line with relevant legislation. We take into account a number of factors including the type of client concerned, the nature of the products to be used and the distribution channel.

Know Your Customer, Investigation and Reporting

We have processes designed to verify our clients' identities and identify unusual or potentially suspicious activity using a variety of methods and technologies. Investigations are performed by a team of experienced independent investigators and reports are made to law enforcement authorities as required. We maintain records of clients and transactions in line with the local regulatory requirements.

All of our management and staff have an obligation to follow our policy and we have a global network of Financial Crime Compliance staff whose job is to provide on the spot advice and guidance on financial crime issues, as well as working with the authorities on specific issues or cases should they arise.

Staff training

Staff receive mandatory financial crime training including how to spot red flags relating to financial crime and how to report it. We use a variety of methods, including web-based tools, to ensure that training is effective, comprehensive, and up to date.

Payments

We do not accept cash receipts or make cash payments under any circumstances. In order to help prevent financial crime, we only permit third party payments in very limited circumstances and only once verification checks have been performed on that third party as well as the customer.