Purpose and Scope
CoolBucks is committed to preventing money laundering and complying with all applicable anti-money laundering laws and regulations. This policy outlines the company’s procedures and controls to identify, assess, and mitigate the risks associated with money laundering and terrorist financing activities. The policy applies to all employees, agents, contractors, and third parties associated with CoolBucks.
Responsibilities
Management Team: The management team is responsible for implementing and overseeing the AML program, ensuring that adequate resources are allocated and that the policy is consistently applied.
AML Compliance Officer: An appointed AML Compliance Officer is responsible for monitoring and managing the AML program, reporting suspicious activities to appropriate authorities, and ensuring ongoing staff training.
All Employees: All employees are expected to be familiar with and adhere to this policy. They are required to report any suspicious activity to the AML Compliance Officer.
Customer Due Diligence (CDD)
CoolBucks will perform thorough customer due diligence before establishing any business relationship. This includes collecting and verifying customer identification, assessing the nature of the customer’s business, understanding the source of funds, and monitoring transactions for unusual or suspicious activity.
Enhanced Due Diligence (EDD)
Enhanced due diligence will be applied to high-risk customers, business relationships, and transactions. This may include obtaining additional information, scrutinizing transactions, and seeking senior management approval for such relationships.
Reporting Suspicious Activity
Employees are required to promptly report any suspicious activity to the AML Compliance Officer. If money laundering or terrorist financing is suspected, the AML Compliance Officer will promptly file a Suspicious Activity Report (SAR) with the appropriate authorities.
Record Keeping
CoolBucks will maintain records of customer identification, transaction history, and any other relevant documentation for a minimum period as required by applicable laws.
Training and Awareness
Regular training programs will be conducted to educate employees about money laundering risks, detection techniques, and the importance of reporting suspicious activities.
Independent Audit and Review
An independent audit of the AML program will be conducted periodically to assess its effectiveness and compliance with applicable laws and regulations.
Sanctions Compliance
CoolBucks will screen customers and transactions against relevant sanctions lists to ensure compliance with international sanctions.
Confidentiality and Whistle-blower Protection
Employees reporting suspicious activities in good faith will be protected from retaliation. Confidentiality will be maintained throughout the reporting and investigation process.
Continuous Improvement
CoolBucks will continuously review and update its AML program to adapt to changes in laws, regulations, and emerging money laundering risks.
Policy Violations
Violations of this policy may result in disciplinary action, up to and including termination of employment.