Anti-Money Laundering Officer

Overall Purpose of Function:

To ensure the Board of Directors, management and employees are in compliance with Laws and Directives issued by the Cyprus Securities and Exchange Commission, that company policies and procedures are being followed.

Key Areas of Activity/Responsibility:

• To implement the company’s procedures and processes for the prevention of Money Laundering and Terrorist Financing.
• To adhere to the Client Acceptance Policy and Due Diligence procedures when assessing prospective client’s applications to open a trading account with the company.
• To monitor and assess the correct and effective implementation of the general policy principles of the company in relation to the prevention of Money Laundering and Terrorist Financing.
• To identify shortcomings and/or weaknesses in the application of the required practices, measures and procedures of the company’s AML manual (Prevention of Money Laundering and Terrorist Financing Manual), and where deemed necessary to inform the Compliance Officer.
• To identify potential areas of compliance vulnerability and risk, develop and implement corrective action plans, in consultation with the Compliance Officer, for the resolution of problematic issues, and provide general guidance on how to avoid or deal with similar situations in the future.
• To provide reports as directed or requested of the operation and progress of compliance efforts.
• To ensure proper reporting of violations or potential violations to duly authorised enforcement agencies as appropriate or required.
• To report information which is considered to be knowledge or suspicion of money laundering or terrorist financing activities. The information is received in a written report form (hereinafter the Internal Suspicion Report).
• To provide advice and guidance to the employees of the company on subjects related to money laundering and terrorist financing.
• To monitor the performance of compliance and adherence to the AML manual, taking appropriate steps to improve its effectiveness.
• To attend seminars and courses in order to acquire the knowledge and skills required for the improvement of appropriate procedures for recognising, preventing and obstructing any transactions and activities that are suspected to be associated with money laundering or terrorist financing.

Internal Relationships

• To collaborate with other departments regarding compliance issues for investigation and resolution.
• To communicate and coordinate with internal departments.
• To attend team meetings and share best practices with colleagues.

External Relationships

• To respond to all requests and queries from MOKAS and to respond to all requests and queries from CySEC.
• To notify the Money Laundering Combat Unit of the Republic (MOKAS) if information is received which is considered to be knowledge or suspicion of money laundering or terrorist financing activities. The procedure is to be followed as per the AML manual.

Administrative

• To prepare and submit the Annual AML Report to Board and CySEC
• To prepare and submit any reports requested by CySEC regarding clients’ account information
• To ensure the timely and proper reporting of FATCA and CRS obligations
• To prepare and correctly submit to CySEC the monthly statement of important transactions in cash, due by the 15^th of each month.