ANTI-MONEY LAUNDERING
AND COUNTER-TERRORISM FINANCING POLICY
OF AUTU SECURITIES INTERNATIONAL INC.
Introduction
Autu Securities International Inc. is firmly committed to maintaining the integrity of its operations by adhering to the AML & CTF Act and the requirements of the Vanuatu Financial Intelligence Unit (VFIU).
This policy establishes the framework for our Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) measures, ensuring our institution is not exploited for illicit purposes.
Our primary objectives are to:
Uphold the highest ethical and professional standards.
Safeguard our products and services from being misused for money laundering or terrorism financing.
Foster a culture of compliance among our staff.
Duty of Vigilance
We recognize our duty under the AML & CTF Act to:
Implement robust policies and procedures to prevent money laundering and terrorism financing.
Monitor, detect, and respond to suspicious activities.
Report any instances of potential misuse to the VFIU promptly.
Our commitment to vigilance ensures the safety and legitimacy of our operations and contributes to global efforts against financial crimes.
Principles
Opposition to Crimes: We strongly oppose money laundering and terrorism financing, refusing to tolerate the misuse of our services for such activities.
Commitment to Compliance: We strictly adhere to Vanuatu’s AML & CTF regulations.
Legitimate Transactions Only: Our products and services are available exclusively for legitimate purposes to individuals or entities whose identities have been verified.
Risk Assessment: We avoid relationships with high-risk individuals or entities based on reasonable assessments.
Staff Support: We provide guidance to staff dealing with transactions involving personal connections.
Equality: Owners, management, and staff are treated the same as any other applicant.
Suspicious Activity Reporting: We promptly report any suspicious activities to the VFIU.
Staff Training: Comprehensive AML & CTF training is provided to ensure all staff understand their responsibilities.
Monitoring and Evaluation: We continuously monitor customer transactions in proportion to their assessed risk levels.
Registration with FIU: We comply with Section 9 of the AML & CTF Act by registering with the FIU and updating them on material changes in our business.
Compliance Officer Reporting: We notify the FIU of any changes to our Compliance Officer as required under Section 34 of the AML & CTF Act.
Screening and Removal: Owners, management, and staff undergo fit-and-proper screening and may be disqualified under Sections 48 and 49 of the AML & CTF Act.
Our AML & CTF Program
Our AML & CTF Program encompasses:
Policies and procedures to verify customer identities.
Ongoing transaction monitoring for unusual activities.
Identification of events requiring additional actions.
Reporting of suspicious activities and compliance with VFIU requirements.
Maintenance of accurate records of all transactions and actions taken.
These controls are integral to our operations and embedded into our product features to ensure effective compliance.
Disciplinary Action and Dismissal
Staff Accountability
Staff members who fail to adhere to AML & CTF policies will face disciplinary actions, including dismissal. Any involvement in facilitating money laundering or terrorism financing will result in immediate dismissal and reporting to the VFIU and law enforcement for prosecution.
Equal Enforcement
All procedures in this manual apply equally, regardless of personal relationships or familiarity with involved parties. Transactions involving acquaintances, owners, or other connections must adhere strictly to these procedures.
Compliance Support
Staff encountering difficulties in following these procedures should consult the Compliance Officer for guidance and support.
Conclusion
Autu Securities International Inc. reaffirms its commitment to combating money laundering and terrorism financing. By adhering to this policy, we ensure the integrity of our operations, protect our customers, and contribute to global financial security.
