Anti Money Laundering Policy
Transparency is a recurring UnityFinance value that is reflected in our pricing promise, our security protocol and our legal agreements.
Transparency is a recurring UnityFinance value that is reflected in our pricing promise, our security protocol and our legal agreements.
UnityF Limited, referred to in this policy as Unity Finance, is committed to identifying and preventing money laundering and terrorist financing through the products and services it provides to clients. This policy sets out how Unity Finance assesses risk, verifies customers, monitors activity and maintains records.
Unity Finance’s anti-money laundering (AML) and counter-terrorist financing (CTF) programme brings together four areas of control: risk assessment, Know Your Client (KYC) checks and customer due diligence, ongoing activity monitoring, and record keeping.
Unity Finance uses a risk-based approach to meet its AML and CTF responsibilities. It identifies, assesses and seeks to understand its exposure to money laundering and terrorist financing, then applies measures suited to the level of risk identified.
Money laundering involves transactions intended to conceal or disguise the nature and origin of funds derived from unlawful conduct, including fraud, corruption, organised crime or terrorism. National law determines the specific offences. The process is commonly described in three stages: placement, layering and integration.
At the placement stage, criminal proceeds are moved into the financial system. Examples include cash deposits with banks or non-bank financial institutions, such as currency exchanges; conversion into instruments such as traveller’s cheques or payment orders; and purchases of valuable items for resale.
Placement may involve depositing cash in a jurisdiction with weaker financial controls before transferring it to a more regulated environment to give it an appearance of legitimacy. Another indicator is the division of a large amount into smaller deposits to avoid reporting thresholds, a practice often called “smurfing”.
Layering creates distance between the proceeds and their criminal source through a sequence of transactions. It is intended to obscure ownership and origin, interrupt the audit trail and preserve anonymity, including by changing the form or location of the funds.
Examples include repeated transfers between financial institutions, early annuity withdrawals despite penalties, cash-secured loans and letters of credit supported by false invoices or bills of lading.
Integration returns the laundered proceeds to the economy as apparently legitimate funds. At this stage, the money becomes available to the criminal again and may circulate without attracting suspicion.
Risk assessments consider the customer, the countries connected with the relationship or transaction, and the services involved. The outcome informs the information collected and the controls applied.
Customer-related warning signs include inconsistent identification details, fictitious or stolen identities, forged documents and discrepancies in documents relating to legal entities. Other indicators include reliance on post box addresses, missing or invalid contact information, a history of financial crime, connections to terrorism and outstanding warrants.
The assessment also considers politically exposed persons (PEPs), including people entrusted with prominent public functions. Examples include heads of state, government ministers, members of parliament, political party leaders, supreme court judges, ambassadors, senior military officers, directors of state-owned enterprises and executives of international organisations.
Under the Anti-Money Laundering Directive referred to this policy, relationships or transactions involving high-risk third countries require enhanced due diligence. This includes obtaining further information about the customer and beneficial owner, establishing the origin of funds and assets, understanding the transaction’s purpose, and securing senior management approval before starting or continuing the relationship.
When evaluating a service, Unity Finance considers the factors that may make it vulnerable to money laundering. The assessment takes account of risks identified by regulators, government bodies and other reputable sources.
Unity Finance establishes customer relationships remotely, without requiring an in-person meeting. Electronic data brokers support identification, alongside internal checks such as identifying duplicate accounts and confirming bank account ownership. These checks support customer identification and the collection of background information about the purpose and nature of the customer’s business with Unity Finance.
Unity Finance collects and records additional customer information where the assessed money laundering risk calls for it. The scope of those enquiries follows the risk-based approach described in this policy.
Unity Finance also determines whether a customer is acting for someone else, including as a trustee, nominee or professional intermediary. Before providing services in those circumstances, Unity Finance must obtain satisfactory evidence of the identity of the intermediary and the individual or entity represented. It must also understand any relevant trust arrangements.
Customer due diligence continues beyond the start of the relationship. Unity Finance monitors customer activity on an ongoing basis to identify conduct that may be suspicious or fraudulent.
Monitoring combines automated tools with manual reviews by Unity Finance staff and, where necessary, external service providers. Status fields assigned to customer accounts support the operation of automated monitoring.
Unity Finance maintains a suspicious activity reporting process through which any employee can notify the Money Laundering Reporting Officer (MLRO) of known or suspected involvement in money laundering or terrorist financing. The process has three components:
Unity Finance keeps the documents collected to identify customers under its KYC requirements, together with transaction data and other information relevant to AML controls, as required by applicable laws and regulations.
The records include suspicious activity reporting files and documentation of AML monitoring. All records must be retained for at least five years.
Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Marshall Islands MH96960
Registration Number: 127542
Email: support@unityfinance.com
