Isabella Jewellers & Refiners

MONEY LAUNDERING & FINANCE OF TERRORISM

PURPOSE
The purpose of the policy is to do all we can to prevent, wherever possible, the organization and its staff
from being exposed to money laundering, to identify the potential areas where it may occur, and to
comply with all legal and regulatory requirements, especially with regards to the reporting of actual or
suspected cases. Money laundering is the attempt to conceal or disguise the nature, location, source,
ownership or control of illegally obtained money. Money laundering is illegal.

SCOPE OF THIS POLICY
This policy applies to all employees and aims to maintain the high standards of conduct, by preventing
criminal activity through money laundering

OBLIGATIONS AND RESPONSIBILITIES

  1. Employees must identify suspicious and unusual transactions.
  2. Report these transactions to Management to investigate.
  3. Identification and verification of clients before transacting.
  4. Keep record of the identification and verification document.
  5. Check the new clients / organization’s website to confirm its business address and any other
    details.
  6. Attending the client at their business address.
  7. Evidence or the personal identity of the key contact person and the organization; If satisfactory
    evidence of identity is not obtained at the outset of the matter then the business relationship or
    one of the transaction cannot proceed any further.
  8. No Payments to third party accounts and cash payments must be signed for by the responsible
    person who was identified as the companies contact person.
  9. IDENTIFICATION AND VERFICATION REQUIREMENTS
  10. All staff who are required to identify and verify clients shall do so in the following manner.
  11. Ensure that the client does not conduct business under false names.
  12. Identify whetherthe clientis a: –
  13. Natural Person.
  14. Natural person acting on behalf ofanother.
  15. Foreign National.
  16. Close Corporation.
  17. South African Company.
  18. Foreign Company.
  19. Other legal Person.
  20. Partnership.
  21. Trust.
  22. RECORD KEEPING PROCEDURE
  23. Client identification document or company documents
  24. Printed record of accountability check to verify the individual or company details
  25. Details of all relevant business transactions carried out for clients for at least five years. This is so
    that they may be used as evidence in any subsequent investigation by the authorities into money
    laundering.
  26. Isabella & Jewellers & Refiners (Pty) Ltd must be capable of providing an audit trail, for example
    distinguishing the client and the relevant transaction and recording in what form any funds were
    received or paid.
    INDIVIDUAL RESPONSIBILITIES
  27. To be alert to where Isabella & Jewellers & Refiners (Pty) Ltd may be targeted by individuals
    trying to launder the proceeds of crime
  28. To report any suspicions of money laundering to Management
  29. It is not your responsibility to decide whether a suspicious transaction actually constitutes money
    laundering.
  30. Failure by any employee or staff member to adhere to any of the requirements and obligations
    contained herein shall result in disciplinary action being taken against the relevant staffmember.
    It is the employee’s responsibility to contact management should he/she have any queries. Employees
    are invited to comment on this policy and suggest ways in which it might be improved. Comments,
    suggestions and queries should be addressed to line Management.

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