AML/CFT Protocol

[SBRAND] is a company that works in accordance with the guidelines of the MONEYVAL – Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism in aim to protect its clients from money spinning and the financing of terrorism.

MONEYVAL is a pan-European monitoring body that appraises compliance with the principal international standards to counter money laundering and the financing of terrorism. With 47 member states, it reports directly to its principal organ – the Committee of Ministers of the Council of Europe. MONEYVAL also judges the effectiveness of the implementation of the regulations, and presents recommendations to national authorities regarding necessary improvements to their systems. In addition to that, MONEYVAL conducts typology research of money laundering and terrorist financing methods, trends and techniques. Originally, the organisation was an only observer to the FATF. Later, it became an associate member as of June 2006. Therefore, [SBRAND] has implemented MONEYVAL procedures to prevent people from laundering money.

Some of the procedures we apply are:

• Ensuring that clients have valid proof of identification and maintaining records of identification information.
• Verifying that clients aren’t terrorists nor suspects by examining the lists of known or suspected terrorists.
• Informing clients that the information they provide may be used to verify their identity.
• Supervising the clients’ money transactions.
• Dismissing cash, money orders, third-party transactions, exchange houses transfers or Western Union transfers. Money laundering occurs when illegal/criminal activity funds are changed to make it seem as if these funds have come from legitimate sources.

How Money Is Normally Laundered:

For money to be laundered, there are several stages. Check them out below.

1. Placement Stage

First and foremost, when cash or its equivalents are moved into accounts (e.g. futures accounts) via financial institutions, through a series of financial transactions. The entire goal of making these transactions is to hide the origin of the money (e.g. executing trades with little or no financial risk or transferring account balances to other accounts).

2. Layering Stage

In the second stage is “layering” aka “structuring stage”. Funds are broken down into small transactions, making it difficult to detect the laundering activity. Nowadays, these funds are used to trade different stocks across different markets to hide the trail. Buying assets and then selling them is considered another effective and common way that criminals use to cover the trail. Assets can be re-sold locally or abroad and hence makes it harder to trace and thus seize.

3. Integration Stage

Integration stage is the final stage of money laundering, in which the money is now returned to the criminals legitimately (e.g. closing a futures account and transferring the funds to a bank account).

Seeing that trading accounts are one of the vehicles that may be used to spin unlawful funds or to conceal the true owner ( by executing financial transactions that obscure the origins of the fund), [SBRAND] directs funds withdrawals back to their original source. These guidelines have been implemented to protect [SBRAND] and its clients, as International Anti-Money Laundering requires financial services institutions to be aware of potential money laundering abuses that could occur in a customer account and implement a compliance program to deter, detect and report potential suspicious activity. For questions/comments regarding these instructions, please contact us at [SEMAIL].