Employees should be sensitive to potential warning signs of money laundering
When establishing and maintaining a relationship or providing services, especially when dealing with a client infrequently all necessary steps must be taken to determine, to verify where necessary and to remain appraised of the identity, financial position and business objectives of the client. Client identification must be carried out before any dealing takes place and the firm's account opening form must be completed and processed for every new account.
The principal officer's accounts will be reviewed by the Board of Directors.
Continuous Due Diligence:
- a. It is the duty of every client manager/client owner to satisfy himself about the soundness and investment objectives of client.
- b. Porfolio/Investment size/order sizes are commensurate with annual income disclosed by client
- c. Maintain continuous familiarity and follow up with clients where any inconsistency in the information is provided.
- d. Verify sources of fund disclosed by client.
- . Every client owner/manager should carry on independent grading of his/her client on periodical basis (12months or 18 months) and intimate compliance department of his finding if there is any adverse change in grading.
Back office members should immediately inform Operations head/Accounts head who in turn will inform Principal Officer about any transaction which is inconsistent with client regular trading or if funds and securities are coming from account other than the account specified by client or if they receive request to transfer fund or security to account other than the designated account. Never make client aware of your suspicion.