1. CORPORATION POLICY
It is the policy of the firm to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities by complying with all applicable requirements under the Banko Sentral ng Pilipinas (BSP) and its implementing regulations.
Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets.
Generally, money laundering occurs in three stages.
- Placement Stage: Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or traveler’s checks, or deposited into accounts at financial institutions.
- Layering Stage: At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.
- Integration Stage: At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.
2. PROGRAM AND PRINCIPLE TO FIGHT MONEY LAUNDERING AND COMPLIANCE WITH LAW
Aunicaj Pay ensures that its business is conducted in conformity with the height of ethical standards, that laws and regulations are respected and complied with whenever possible, and that service is not provided where there is good reason to believe that transactions are associated with money laundering activities.
The Corporation has designated personnel as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AMLA program. The personnel have a working knowledge of the BSP and its implementing regulations and is qualified by experience, knowledge and training.
Aunicaj Pay endeavors to apply the following principles in order to detect, prevent and oppose the use of the Company’s services for money laundering and terrorist financing:
- Established and duly appointed Compliance Office
- Know-Your-Customer (CDD and EDD)
- Reporting to AMLC
- Ongoing Employee Training
- Ongoing monitoring and Compliance Testing
- Record Keeping and Data retention in accordance with AML laws and regulations
- Internal Audit Function
3. CUSTOMER IDENTIFICATION PROGRAM
We will collect certain minimum customer identification information from each customer who opens an account; utilize risk-based measures to verify the identity of each customer who opens an account; record customer identification information and the verification methods and results; provide the required adequate CIP (Customer Identification Program) notice to customers that we will seek identification information to verify their identities;
a. Required Customer Information
Prior to activating an account, [Name of person or category of associated person] will collect the following information for all accounts, if applicable, for any person, entity or organization that is opening a new account and whose name is on the account:
(1) the name;
(2) date of birth (for an individual);
(3) an address, which will be a residential or business street address (for an individual),
(4) an identification number, which will be a taxpayer identification number, government issued ID and latest image holding the valid ID.
b. Customers Who Refuse to Provide Information
If a potential or existing customer either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, our Company will not activate his account and, after considering the risks involved, consider closing any existing account.
c. Verifying Information
Based on the risk, and to the extent reasonable and practicable, we will ensure that we have a reasonable belief that we know the true identity of our customers by using risk-based procedures to verify and document the accuracy of the information we get about our customers. AMLA Personnel will analyze the information we obtain to determine whether the information is sufficient to form a reasonable belief that we know the true identity of the customer (e.g., whether the information is logical or contains inconsistencies).
We will verify customer identity through documentary means, non-documentary means or both. We will use documents to verify customer identity when appropriate documents are available.
d. Lack of Verification
When we cannot form a reasonable belief that we know the true identity of a customer, we will do the following: (1) not activate an account; (2) impose terms under which a customer may conduct transactions while we attempt to verify the customer’s identity;
4. SHARE AMLA INFORMATION AND COOPERATE TO GOVERNMENT LAW ENFORCEMENT AGENCIES
We will share information with other financial institutions regarding individuals, entities, organizations and countries for purposes of identifying and, where appropriate, reporting activities that we suspect may involve possible terrorist activity or money laundering.
Within the legal constraints relative to client confidentiality, Aunicaj Pay cooperates with law enforcement agencies. This includes taking appropriate measures within the law if there are reasonable grounds for suspecting money laundering. Any disclosure made in conjunction with the Act shall be made to the Executive Director of the Anti-Money Laundering Council of the Bangko Sentral ng Pilipinas.