Know Your Customer (KYC) or Know Your Customer Counter Party (KYCC) Policy We believe KYC and KYCC are effective defences against money laundering and terrorist financing.
MoneyFex ensures that the key information and documents required to support effective KYC and KYCC include:
MoneyFex staff shall always sight the original ID from the Sender, and initial a copy of the ID as "True Copy".
In rare events or incidents where a Customer fails to provide adequate KYC information, or appears hesitant/unwilling to provide information as required to establish adherence to KYC norms, MoneyFex shall not proceed with such a transaction, and flag the case as a High Risk customer. Such cases are marked for reporting to the Regulator through Suspicious Activity Report (SAR), and for increased monitoring.
MoneyFex shall perform due diligence before onboarding a customer or establishing business relationships with the correspondent banks, service providers and business partners.
MoneyFex shall perform Enhanced Due Diligence in the following scenarios:
The above scenarios are reviewed periodically and updated as required.
MoneyFex's remittance system/AML solution has the capability to search and store data from watch lists such as OFAC, UN, EU, HMRC and the list of names issued by Bank of England and Law enforcement.
Internal Black list: Additionally, to support and comply with demand from competent authorities as required, the system has the capability to maintain an internal blacklist to "add" or "remove" the names as communicated by the authorities.
The lists are updated on a daily basis if there are notices/alerts from regulatory authorities for the purpose of screening the names to identify the individuals, entities, organisations who may pose a high risk to the global community/financial systems.
MoneyFex shall file a suspicious transaction report to the Regulator if there are reasonable grounds to suspect that the proceeds are from the outcome of any of the illegal activities and/or the transaction is intended for terrorist financing/activities.
MoneyFex shall not enter into a business relationship with any of the shell company/ shell bank/ shell service provider. For the existing customers, during the course of business relationship if there are reasonable grounds to believe that the client/service provider is involved in any of the illegal activities, relationship with such clients / service providers, will be suspended/terminated with immediate effect and will be reported to the regulatory authority.
MoneyFex shall not conduct any transaction to/from any Sanction body and will not undertake/accept any transaction to/for individual, entity and/or (SDN's) which are black listed by the local and/or any of the international regulatory authorities.
Financial transactions of Politically Exposed Person generally possess high risk due to the possible involvement in bribery and/or corruption. Hence, onboarding of PEP customers requires compliance clearance and senior management approval. At the transitional stage, it requires proper satisfactory supporting documents to substantiate the transaction. Failure to comply with the supporting documents by the customer shall be reported to the regulator.
MoneyFex shall enter into a correspondent banking/Agent relationship only after considering the following factors and with the approval of the Management:
In addition to the above, MoneyFex will also obtain an approval from the Regulator of the UK before commencement of relationship with them.
MoneyFex has a self-attested KYC/AML/CTF Questionnaire drafted in line with the Wolfsberg KYC principle, regulatory requirements of the UK and other international regulatory bodies. These questionnaires are subject to frequent reviews and modifications to accommodate the regulatory and/or industry changes.
