YOUR CLIENTS Clause Samples

YOUR CLIENTS. The Financial Intelligence and Anti-Money Laundering Act 2002 (the “FIAMLA”) and the Financial Intelligence and Anti-Money Laundering Regulations 2018 (the “FIAML Regulations”) obligates the Company to perform a thorough due diligence on its clients. The FSC has also issued an Anti-Money Laundering and Combatting the Financing of Terrorism Handbook 2020 which was updated in September 2022 to guide reporting persons on anti-money laundering, financing of terrorism and financing of proliferation of weapons of mass destruction. By having effective systems and controls in place and having sound due diligence measures, the Company will be able to prevent and detect money laundering and terrorist financing. To ensure compliance with the applicable Anti-Money Laundering legislations, the Company and its Administrator in Mauritius shall require a detailed verification of a prospective Client’s identity and the source of payment for each transaction during the initial transaction and also on an ongoing basis. The Company has developed a risk-based due diligence approach for client acceptance. This involves the identification and verification of the clients. CDD is the process used to identify, verify, and understand the clients. The Clients shall also be screened on risk intelligence databases and against UN Sanctions list. The Company will require detailed verification of a Client and its owners’ identities before any transaction can be executed. This becomes more important in the event (i) a payment is received from an account in the name of a person or persons other than the Client; or (ii) appears that the Client is acting on behalf of some other person. Verification of the identity of the Client or the person on whose account such amount is being received is required. For the list of the documents to be required on Clients, reference is to be made to the Company’s Policies and Procedures Manual. The type of due diligence measure to be applied to a client will depend on the risk such client represents to the Company. For example, simplified due diligence may be applied where risk is low but the simplified CDD measures shall be commensurate with the lower risk factors and in accordance with any guidelines issued by the FSC, Financial Intelligence Unit (the “FIU”) or any other supervisory authority. It shall be ensured that the low risk identified is in accordance of the national risk assessment (the identification, assessment and understanding of the national mo...