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TITANBIT LIMITED ANTI MONEY LAUNDERING AND COUNTER TERRORIST FINANCING POLICY("AML") AND ("CTF")

 

Criminals use financial institutions to conceal their illegitimate funds with the aim of making dirty money clean, this is known as money laundering. Terrorism financing is the financial support of terrorism or of those who encourage, plan, or engage in terrorist activities.

 

SANCTIONS POLICY

 

Titanbit is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. Titanbit will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.

UK AML LEGAL AND REGULATORY FRAMEWORK:

The UK AML regime is set out in the following legislation and regulations:
The Proceeds of Crime Act 2002 (POCA), as amended by the:
 i. Serious Organised Crime and Police Act 2005 (SOCPA); and the
 ii. Proceeds of Crime Act (Amendment) Regulations 2007;
The Terrorism Act 2000, as amended by the:
 i. The Anti Terrorism, Crime & Security Act 2001; and the
 ii. Terrorism Act (Amendment) Regulations 2007;
The Terrorism Act 2006;
The Money Laundering Regulations 2007; and
The Joint Money Laundering Steering Group (JMLSG) Guidance for the UK Financial Sector on the prevention of money laundering/combating terrorist financing.

ANTI-MONEY LAUNDERING (AML) POLICY:

The Titanbit AML Policy is designed to prevent money laundering by meeting the UK AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
The maintenance of appropriate records for the minimum prescribed periods;
Training and awareness for all relevant employees.