LCTL has a strong regime to fight money laundering and terrorism financing. Compliance Dept is the policy unit responsible for adhering to Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001 (AML/CTF Act) and the Guidelines on Anti Money Laundering and Counter Financing of Terrorism (Trust Company Sector) issued by LFSA.
In establishing relationship with potential clients and continuing relationship with existing clients, LCTL has some level of AML/CFT obligations and must discharge the compliance obligations seriously.
Satisfying the requirements of AMLCFT acts and guidelines include
- Customer Due Diligence (CDD)/Know Your Procedures
A guide for relevant employee to know basic documents and information that must be collected from a customer before accepting the customer.
- Enhanced Customer Due Diligence Procedure
To provide enhanced steps to be taken when a customer is classified as a high risk customer
- Company Principles, Roles and Responsibilities Procedure
Explaining the roles and responsibilities of the Board of Directors, Senior Management and Compliance Officer and guiding guide all staff on the level of integrity, and the conduct and behaviour expected of them in upholding the Company’s reputation.
- Risk Based Approach (RBA) Customer Assessment Procedure Manual
Explaining factors to consider in assessing risk before accepting a customer, explaining how risk ratings are applied, explaining how to recognize PEP and its treatment, stating the risk review schedule
- On-Going Due Diligence Of Customers Procedure
Guiding staff on how to ensure the company’s continuing knowledge of their customers through periodic RBA review of customers’ information
- Suspicious Transaction Report
Explaining what amounts to suspicious activities and how suspicious activities will be reported as well as follow-up action.
- Record Keeping Procedure
Explaining what records to be kept, how long and where to keep.
- Staff AML/CFT Training and Awareness Procedure
Explaining to all staff on the AML/CFT Training Programme enforced by the company and the type, level and frequency of AML/CFT training that will be conducted
- Red Flags Identification Procedure
Explaining what kind of activities may be classified as suspicion which will prompt reporting to be made.