This policy applies to all officers, employees, appointed producers, and the products and services offered by Angel Markets. All business units and locations within Angel Markets will work together to create a unified effort in the fight against money laundering. Each business unit and location has implemented risk-based procedures designed to prevent, detect, and report suspicious transactions. All efforts made will be documented and retained. The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (‘SARs’) or other required notifications to the appropriate law enforcement or regulatory agencies. Any inquiries from law enforcement or regulatory agencies regarding this policy should be directed to the AML Compliance Committee.
Angel Markets is committed to actively preventing money laundering and any activities that facilitate money laundering or the funding of terrorist or criminal activities. We require all officers, employees, and appointed producers to adhere to these standards to prevent the misuse of our products and services for money laundering purposes.
For the purposes of this policy, money laundering is defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds, making them appear as if they originated from legitimate sources.
Money laundering is the process by which criminally obtained money or assets (criminal property) are converted into “clean” money or assets that have no obvious link to their criminal origins. Criminal property can take various forms, including money, securities, tangible property, and intangible property. It also includes any money, regardless of its source, used to fund terrorism.
Money laundering is not limited to a single stage; methods can range from purchasing luxury items like cars or jewellery to moving money through complex legitimate operations. Typically, the process starts with cash but can involve any legal form of property, whether money, rights, real estate, or other benefits. If you know or suspect that property was obtained through criminal activity and do not report it, you are participating in the money laundering process.
No financial institution is immune to the activities of criminals, and firms should assess the money laundering risks associated with the products and services they offer.
Terrorist financing involves legitimate businesses and individuals providing funding for terrorist activities or organisations for ideological, political, or other reasons. Firms must ensure that (i) customers are not terrorist organisations themselves, and (ii) they are not facilitating funding for terrorist organisations.
Terrorist financing may not involve proceeds from criminal conduct, but rather an attempt to conceal the source or intended use of funds that may later be used for criminal purposes.
The level of due diligence required in anti-money laundering procedures should follow a risk-based approach. This means that the resources allocated to due diligence in any relationship should correlate with the magnitude of the risk posed by that relationship.
These risks can be categorised as follows:
Customer Risk : Different customer profiles carry varying levels of risk. A basic Know Your Customer (KYC) check can establish the risk associated with a customer. For example, near-retired individuals making small, regular contributions to a savings account represent a lower risk compared to middle-aged individuals making irregular, large payments inconsistent with their financial profile. Higher scrutiny is warranted for higher-risk profiles, such as corporate structures, which may hide the source of funds.
Product Risk : The risk associated with the product or service itself, driven by its potential use as a money laundering tool. The Joint Money Laundering Steering Group categorises products into three risk bands: reduced, intermediate, and increased. For instance, pure protection contracts are generally considered reduced risk, while investments in unit trusts are classified as increased risk.
Country Risk : The geographic location of the client or the origin of business activities is associated with risk due to varying levels of risk across different countries.
Firms will determine the extent of their due diligence measures based on these four risk categories.
When establishing a business relationship, it is crucial for the company to understand the nature of the business a client intends to conduct. Once a business relationship is formed, any regular activity can be assessed against the expected pattern of the customer’s behaviour. Unexplained activity may then be examined for potential money laundering or terrorist financing concerns.
Information regarding a client’s income, occupation, source of wealth, trading habits, and the economic purpose of transactions will typically be collected as part of the advisory process. Personal information, such as nationality, date of birth, and residential address, will also be gathered at the outset of the relationship, factoring in the risk of financial crime, including AML and CTF. For high-risk transactions, verification of the provided information may be warranted.
Verification of the obtained information must rely on reliable and independent sources, which may include documents provided by the customer, electronic verification by the firm, or a combination of both. In face-to-face transactions, original documents should be reviewed.
Documents issued by government agencies, such as passports or national identity cards, provide a higher level of confidence in verifying identity. If such documentation is unavailable, other identity evidence may be considered, weighing the associated risks.
Angel Markets does not set a deadline for clients to submit their verification documents; however, submission is a prerequisite for fund withdrawal. We commit to reviewing submitted documents within 24 hours of receipt.
