Korusun Traders

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.