ANTI-MONEY LAUNDERING POLICY
Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policies
Money laundering and terrorist financing have been identified as major threats to the international financial services community. South Africa, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for SA firms and outline the offences and penalties for failing to comply. Qwikpay (Pty) Ltd is authorized and regulated by the South African Reserve Bank. (SARB) Qwikpay (Pty) Ltd and its branches and subsidiaries trade as https://qwikpay.org and Qwikpay (Pty) Ltd. Further, some branches and subsidiaries are listed and/or regulated. Qwikpay (Pty) Ltd is a member of the Gilcrest Trade Group, an association of payment processors, aimed to develop financial services industry standards for Know Your Customer (KYC), AML and CTF.
Gilcrest Trade Group Policies & Principles
The Financial Crime Team owns and is responsible for the following Group Policies covering:
- Anti-Money Laundering/Counter-Terrorist Financing/Counter-Proliferation Financing;
- Anti-Bribery & Anti-Corruption;
These policies and principles are designed to ensure that all Group Companies comply with the legal and regulatory requirements applicable in South Africa as well as with their global obligations.
- Anti-Money Laundering (AML) Policy
The Gilcrest Trade Group AML Policy is designed to ensure that all Group Companies comply with the requirements and obligations set out in legislation, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by all Gilcrest Trade Group Companies and includes:
- The appointment of a Group Money Laundering Reporting Officer (GMLRO) and Business Unit Money Laundering Reporting Officers (MLROs) of sufficient seniority, who have responsibility for oversight of Group and Business Unit compliance with relevant legislation, regulations, rules and industry guidance;
- Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the Group;
- Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;
- Establishing and maintaining risk based systems and procedures to monitor ongoing customer activity;
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- The maintenance of appropriate records for the minimum prescribed periods;
- Training and awareness for all relevant employees;
- The provision of appropriate management information and reporting to senior management of the Group’s compliance with the requirements;
- Anti-Bribery & Anti-Corruption Policy Corruption is often associated with organized crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.
Gilcrest Trade Group is committed to applying high standards of honesty and integrity consistently across us global operations and in all our business dealings.
- Introducer Policy
In addition to the Anti-Bribery and Anti-Corruption Policy, Gilcrest Trade Group has an Introducer Policy. The Policy covers the activities of all third parties that generate or retain business, or secure a business benefit, for Gilcrest Trade Group. These third parties are termed “introducers” by Gilcrest Trade Group. Potential examples would include senior advisors, lead generators and financial advisers. The Gilcrest Trade Group Introducer Policy is designed to protect Gilcrest Trade Group against the bribery and corruption risks, reputational risk, and wider operational and conduct risks associated with introducers. Gilcrest Trade Group employees must apply the specific controls and procedures set out in the policy.
Group Governance & Conformance: Regular reviews of the effectiveness of these Group Policies are carried out in addition to audits periodically undertaken by the Internal Audit function. This provides senior executive management oversight committees and the Board Audit Committee with the necessary assurance regarding the operating effectiveness of the Group’s controls relating to these policies. .