1.1 Purpose
To prevent and detect money laundering, terrorist financing, and any illicit financial activity through the services of Korusun Traders across Pakistan and the UAE.
1.2 Governance & Responsibilities
- Board of Directors: Ultimate oversight of AML framework.
- Compliance Officer (CO): Implements AML policy, oversees KYC, conducts risk assessments, reports suspicious activity.
- Staff: Must comply with AML training, report red flags to the CO.
1.3 Risk-Based Approach
- Client risk profiles are classified as Low, Medium, or High, based on factors such as geography, transaction amounts, and business type.
- Higher-risk clients require enhanced due diligence.
1.4 Customer Due Diligence (CDD)
- Standard CDD (for low/medium-risk clients): verification of identity, address, and beneficial ownership.
- Enhanced Due Diligence (EDD) (for high-risk clients, e.g., PEPs, complex business structures): additional data collection, senior management approval, and transaction monitoring.
1.5 KYC Processes
- Individuals: Government-issued ID, date of birth, address proof.
- Businesses: Certificate of registration, board resolution, directors’ IDs, UBO documentation.
- Ongoing due diligence: Annual updates or upon significant changes.
1.6 Monitoring & Reporting
- Transaction monitoring: Automated systems analyze country risk, volumes, frequency.
- Suspicious Activity Reports (SARs): Filed with regulatory authorities within 24–72 hours.
- Threshold-based reporting: e.g., transactions ≥ USD/Pkr equivalent of 50,000.
1.7 Record-Keeping
- Maintain records for at least 5 years post-relationship termination or until completion of investigations.
- Secure storage of CDD and transaction history.
1.8 Training & Awareness
- Mandatory AML training at onboarding and annually thereafter.
- Updates communicated when regulations or systems change.
1.9 Independent Audit
- The AML program is audited annually by an independent firm to evaluate effectiveness and compliance.
1.10 Sanctions & PEP Screening
- Universal screening for client onboarding and transactions against global watchlists (e.g., UN, OFAC, local).
1.11 Policy Review
- Reviewed at least annually or when there’s a change in legal/regulatory environment.