Compliance function in each country has oversight of all activities relating to prevention and detection of money laundering and terrorist financing including:
• seeking compliance with this Policy and applicable laws and regulations;
• informing senior management of emerging AML/CTF risks and compliance initiatives, as well as identified compliance deficiencies and corrective action taken;
• conducting annual anti-money laundering and terrorist financing risk assessments, in particular:
- formally documented assessments segmented by products, delivery channels, types of customer and geographic location of customers
- customer due diligence procedures including identification of new customers, beneficial owners and beneficiaries
- customer profiling and collection of “Know Your Customer” information
- additional due diligence is undertaken in relation to high risk customers
- transaction monitoring procedures are in place and how alerts are reviewed
- determining how existing customer files are updated in relations to “Know Your Customer” information
- appropriate monitoring of the policy and procedure
- training provided to Employees
• provide for appropriate training to all relevant employees, in particular adequate level of training for employees that complete reports, grant exemptions, monitor for suspicious activity, or engage in any other activity that forms part of FWD’s AML/CFT programme;
• generates the information needed by senior management to obtain an overview with respect to risk management and compliance at a minimum on a quarterly basis; and
• taking appropriate action when breaches of this Policy are identified.