Policy on AML and CFT

The Commitment to the Better World

Executive Summary

The Executive Summary of the Anti-Money Laundering (AML) policy for WIBS App, operated by WIBS International Ltd., encapsulates the essence and significance of the policy in safeguarding the integrity of the financial system and upholding regulatory compliance. At its core, this summary serves as a compass, guiding stakeholders through the principles, objectives, and operational framework of the AML policy.

In today’s globalized economy, where financial transactions traverse borders seamlessly, the threat of illicit funds entering the legitimate financial system looms large. Recognizing this, WIBS International Ltd. has formulated a robust AML policy as a proactive measure to mitigate such risks. The essence of this policy lies in its comprehensive approach towards identifying, preventing, and reporting activities associated with money laundering and terrorist financing.

At its foundation, this summary underscores the fundamental importance of the AML policy in maintaining the integrity and reputation of WIBS App. By adhering to stringent AML regulations, the company not only fulfills its legal obligations but also fosters trust and confidence among its customer base and relevant authorities. It reinforces the commitment of WIBS International Ltd. to operate with the highest standards of ethics, transparency, and accountability.

Furthermore, this summary provides a concise overview of the key components of the AML policy, including customer due diligence, sanctions screening, suspicious transaction reporting, staff training, compliance monitoring, and risk assessment. Each of these elements plays a crucial role in fortifying the defense mechanisms against financial crime and ensuring regulatory compliance at every stage of operation.

Management Commitment

The Management Commitment section of the Anti-Money Laundering (AML) policy for WIBS App, under the stewardship of WIBS International Ltd., delineates the company’s unwavering dedication towards recognizing and addressing the menace of money laundering and associated illicit activities. It serves as a testament to the proactive stance adopted by the company’s leadership in fostering a culture of compliance, integrity, and accountability across all levels of the organization.

WIBS International Ltd. acknowledges that combating money laundering is not merely a regulatory obligation but a paramount responsibility entwined with its core values and business ethos. The recognition of AML as a significant management imperative underscores the company’s commitment to upholding the integrity of the financial system, safeguarding its reputation, and protecting the interests of its stakeholders.

Central to this commitment is the establishment of a robust governance framework that empowers designated officers to spearhead AML initiatives and ensures the allocation of adequate resources for their effective implementation. By appointing a dedicated officer tasked with overseeing AML measures, the company demonstrates its resolve to instill accountability and drive organizational-wide awareness of AML-related risks and obligations.

Moreover, the Management Commitment section articulates the company’s proactive approach towards adopting best practices and staying abreast of evolving regulatory requirements and industry standards. It underscores the importance of fostering a culture of continuous improvement, where feedback mechanisms are leveraged to refine AML processes, enhance detection capabilities, and strengthen internal controls.

Beyond regulatory compliance, WIBS International Ltd. views its commitment to AML as integral to its broader mission of promoting financial inclusion, fostering trust in the digital asset ecosystem, and contributing to the stability and resilience of the global financial landscape. By embracing AML as a strategic imperative, the company seeks to fortify its competitive advantage, attract discerning customers, and foster long-term sustainability in an increasingly complex and interconnected financial environment.

In essence, the Management Commitment section serves as a cornerstone of the AML policy, embodying the company’s ethos of principled leadership, proactive risk management, and unwavering dedication to the highest standards of corporate governance and ethical conduct. It underscores WIBS International Ltd.’s steadfast resolve to combat financial crime, uphold regulatory compliance, and safeguard the interests of its stakeholders, thereby reinforcing trust and confidence in its operations.

The Customer Due Diligence Policy entails comprehensive guidelines for conducting thorough due diligence on customers, implementing a risk-based approach for onboarding new clients, and emphasizing ongoing monitoring and analysis of customer transactions to detect and mitigate potential risks associated with money laundering and terrorist financing.

Sanctions Screening and Asset Freezing

Procedures for Screening Transactions Against Sanctions Lists:

This entails establishing robust mechanisms for systematically screening all transactions conducted through WIBS App against various sanctions lists issued by relevant regulatory authorities, such as governmental bodies and international organizations. These lists typically contain individuals, entities, and countries subject to economic sanctions due to their involvement in activities deemed detrimental to international security, human rights, or other critical interests. By implementing automated screening processes and manual reviews where necessary, the company can swiftly identify and prevent transactions involving sanctioned parties, thereby mitigating the risk of inadvertently facilitating illicit financial activities.

Measures for Freezing Assets Related to Terrorism or Other Illicit Activities:

In the event of suspicion or confirmation of assets associated with terrorism or other illicit activities, WIBS International Ltd. implements immediate measures to freeze such assets, thereby preventing their further utilization or transfer. This involves swift communication and collaboration with relevant authorities, including law enforcement agencies and relevant bodies, to ensure compliance with legal requirements and facilitate the timely freezing of assets linked to criminal activities. Additionally, the company maintains robust internal protocols for investigating and verifying suspected cases of asset-related misconduct, thereby reinforcing its commitment to combating financial crime and safeguarding the integrity of the financial system.

Compliance with AML Laws

Commitment to Comply with the Prevention of Transfer of Criminal Proceeds Act and Other Relevant Regulations:

WIBS International Ltd. pledges commit the best effort to uphold the provisions outlined in the Prevention of Transfer of Criminal Proceeds Act and other pertinent AML laws and regulations. This commitment encompasses a proactive approach to staying abreast of evolving legal frameworks and incorporating necessary changes into the company’s operational procedures and policies. By fostering a culture of compliance, the company aims to mitigate the risk of inadvertently facilitating money laundering activities and uphold its integrity as a responsible financial institution operating within the bounds of the law.

Measures for Refusing or Terminating Transactions in Accordance with Legal Requirements:

In alignment with relevant mandates, WIBS International Ltd. establishes clear protocols for refusing or terminating transactions that raise suspicions of money laundering or other illicit activities. These measures include robust customer due diligence processes, transaction monitoring systems, and escalation procedures to promptly identify and address potential risks. In cases where transactions are deemed non-compliant with AML laws or relevant guidelines, the company takes decisive action to refuse or terminate such transactions, thereby mitigating associated risks and fulfilling its legal obligations. Additionally, WIBS International Ltd. ensures transparency and accountability in its decision-making processes, with a focus on safeguarding the interests of its stakeholders and maintaining the integrity of its operations.

Suspicious Transaction Reporting

Procedures for Monitoring Transactions:

WIBS International Ltd. implements comprehensive systems and processes for continuously monitoring all transactions conducted through its platform. These monitoring mechanisms utilize advanced technology and algorithms to scrutinize transactional data timely, flagging any unusual or potentially suspicious activities for further investigation. By analyzing various transaction parameters, such as transaction amounts, frequency, counterparties involved, and geographic locations, the company can identify patterns indicative of potential money laundering or other illicit activities.

Reporting Suspicious Activities to Relevant Authorities Promptly:

Upon detecting any transactions deemed suspicious based on predefined criteria or manual review, WIBS International Ltd. ensures prompt reporting to the relevant relevant authorities. The company maintains clear escalation protocols and channels of communication with relevant bodies to facilitate the timely submission of suspicious transaction reports (STRs) or other required disclosures. These reports contain detailed information regarding the nature of the suspicious activity, parties involved, transactional details, and any additional pertinent information gathered during the investigation process. By promptly reporting suspicious activities, the company fulfills its legal obligations and contributes to broader efforts to combat financial crime, enabling relevant authorities to take appropriate action to mitigate associated risks and preserve the integrity of the financial system.

Role of the Internal Audit Department in Monitoring Overall Compliance with the AML Policy:

WIBS International Ltd. assigns a pivotal role to its internal audit department in ensuring adherence to the AML policy. The internal audit team conducts regular and systematic reviews of the company’s AML processes, procedures, and controls to assess their effectiveness and identify areas of improvement. By leveraging their expertise and independence, the internal auditors provide objective assessments of the company’s compliance with relevant requirements and internal policies. Their oversight helps to mitigate risks, enhance operational efficiency, and maintain the integrity of the AML framework.

Continuous Improvement Based on Audit Findings:

The findings and recommendations derived from internal audits serve as catalysts for continuous improvement initiatives within WIBS International Ltd. Upon identifying deficiencies or areas for enhancement, the company proactively implements remedial actions and updates its AML policies and procedures accordingly. This iterative process ensures that the company remains adaptive to evolving regulatory landscapes and emerging threats related to financial crime. By embracing a culture of continuous improvement, WIBS International Ltd. demonstrates its commitment to staying ahead of illicit activities and safeguarding the interests of its stakeholders.

Periodic Assessment of Money Laundering and Terrorist Financing Risks Associated with the Company’s Operations:

WIBS International Ltd. conducts regular and systematic assessments to evaluate the potential money laundering and terrorist financing risks inherent in its operations. These assessments consider various factors such as the nature of products and services offered, customer demographics, geographic locations, and transaction volumes. By leveraging risk assessment methodologies, including quantitative analysis and qualitative judgment, the company identifies and prioritizes areas of heightened risk. These assessments are conducted periodically to ensure that risk profiles remain up-to-date and reflective of evolving threats and regulatory changes.

The Risk Assessment section is instrumental in informing the development and implementation of risk-based controls and measures tailored to mitigate identified risks effectively. By adopting a risk-based approach, WIBS International Ltd. can allocate resources more efficiently, focusing on areas of highest risk while optimizing operational effectiveness and relevant compliance. Moreover, the company’s commitment to periodic risk assessments underscores its proactive stance in safeguarding against financial crime and maintaining the integrity of the global financial system.

Risk Assessment

Periodic Assessment of Money Laundering and Terrorist Financing Risks:

WIBS International Ltd. conducts regular evaluations to analyze the susceptibility of its operations to money laundering and terrorist financing activities. These assessments consider factors such as the nature of services provided, customer demographics, transaction patterns, and emerging threats. By periodically reviewing these risk factors, the company can stay vigilant against evolving tactics used by criminals to exploit vulnerabilities within the financial system.

These assessments are pivotal in enabling WIBS International Ltd. to tailor its risk management strategies effectively. By understanding and prioritizing risks, the company can allocate resources appropriately and implement targeted controls to mitigate identified threats. Moreover, the periodic nature of these assessments ensures that risk profiles remain current and reflective of the dynamic landscape of financial crime.

Consequences for Non-Compliance with the AML Policy:

WIBS International Ltd. maintains a zero-tolerance approach towards non-compliance with its AML policy. Employees are expected to adhere to the highest standards of integrity and relevant compliance in all aspects of their work. Non-compliance with the AML policy, whether intentional or due to negligence, is considered a serious offense and may result in disciplinary action.

Review and Revision
Process for Regular Review and Updating of the AML Policy

WIBS International Ltd. establishes a structured process for periodically reviewing and updating the AML policy. This process involves designated stakeholders, such as compliance officers, legal experts, and senior management, who collaborate to assess the effectiveness of existing policies and identify areas for enhancement. The company conducts these reviews at regular intervals, ensuring that the AML policy remains current and reflective of evolving relevant requirements and emerging threats.

Reflect Changes in Regulations or the Company’s Risk Profile:

The review process considers changes in regulations, industry best practices, and the company’s risk profile. Regulatory updates, such as amendments to AML laws or guidelines issued by relevant authorities, are carefully analyzed to determine their implications for the AML policy. Additionally, changes in the company’s risk profile, such as shifts in business activities or emerging risks, are taken into account to ensure that the policy remains robust and relevant.It’s important to note that WIBS International Ltd. reserves the right to dynamically change the AML policy without prior notice to users. This flexibility allows the company to swiftly adapt to regulatory changes and emerging risks, thereby strengthening its defenses against financial crime and ensuring ongoing compliance. While users may not receive explicit notification of policy changes, they are encouraged to periodically review the AML policy on the company’s website to stay informed about any updates.

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