Summary of the Anti-Money Laundering & Counter Terrorist Financing Policy
Eqwire UK Limited ("Eqwire") is dedicated to maintaining a secure and compliant financial environment by implementing robust Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) measures. As an FCA-authorized Electronic Money Institution (EMI), we adhere to the UK's Money Laundering Regulations (MLRs) 2017, as amended, and meet international standards set by the Financial Action Task Force (FATF).
Our AML/CTF Policy provides a comprehensive framework to prevent our services from being used for financial crime, ensuring compliance with applicable laws and safeguarding the trust of our customers and partners.
Our Commitment
Eqwire is committed to detecting, preventing, and reporting any activities related to money laundering, terrorist financing, or other financial crimes. We proactively implement measures to ensure that our business is not exploited for illicit purposes, while fostering a strong culture of compliance across the organization.
Key Features of Our AML/CTF Policy
1. Risk-Based Approach
Eqwire employs a risk-sensitive approach to identify and mitigate risks associated with money laundering and terrorist financing. This includes:
Conducting comprehensive Business-Wide Risk Assessments (BWRA) to identify high-risk areas.
Tailoring controls and procedures proportionately to mitigate these risks effectively.
Ensuring enhanced scrutiny and due diligence for high-risk customers, jurisdictions, or transactions.
2. Customer Due Diligence (CDD)
Eqwire implements rigorous CDD measures, including:
Verification of customer identities for both individuals and small-to-medium-sized businesses (SMBs).
Screening against sanctions lists, Politically Exposed Persons (PEP) lists, and adverse media.
Enhanced Due Diligence (EDD) for high-risk customers and transactions, including detailed assessments of sources of funds and wealth.
Periodic and event-driven reviews to ensure customer information remains accurate and up-to-date.
3. Transaction Monitoring
We deploy advanced automated systems combined with manual oversight to monitor transactions. Our system detects unusual patterns, suspicious activities, and transactions involving high-risk jurisdictions. Alerts are generated for review and, where necessary, escalated to the Money Laundering Reporting Officer (MLRO).
4. Suspicious Activity Reporting
Our MLRO, Sergiu Sagaidac, oversees the reporting of Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) in line with the Proceeds of Crime Act 2002 (PoCA). All employees are trained to recognize and report suspicious activities promptly to ensure regulatory compliance.
5. Governance and Oversight
The Eqwire Board of Directors and Senior Management are actively involved in overseeing the firm's AML/CTF efforts. Key governance elements include:
Appointment of Sergiu Sagaidac as MLRO to manage day-to-day compliance.
Regular reporting to the Executive Risk & Compliance Committee and Board on the effectiveness of systems and controls.
Adherence to a "Three Lines of Defence" model to ensure robust compliance practices.
6. Employee Training
We provide ongoing AML/CTF training to all employees to ensure they understand their responsibilities and can identify and respond to financial crime risks effectively. This training is tailored to different roles within the organization and is updated regularly to reflect evolving regulations.
7. Record Keeping and Data Protection
Eqwire maintains accurate and comprehensive records of customer information, due diligence processes, and suspicious activity reports for a minimum of five years. We ensure that our data handling practices comply with UK Data Protection laws and the GDPR.
8. Sanctions and Proliferation Financing
Eqwire adheres to all applicable UK and international sanctions regimes, including the Office of Financial Sanctions Implementation (OFSI) and FATF guidelines. Our controls ensure we do not process transactions involving sanctioned parties or high-risk jurisdictions.
Scope of the Policy
This policy applies to all Eqwire employees, contractors, and third-party service providers involved in delivering our e-money services. It is designed to ensure compliance with applicable UK and European regulations, including:
The Money Laundering, Terrorist Financing, and Transfer of Funds Regulations 2017 (and subsequent amendments).
Proceeds of Crime Act 2002 (PoCA).
The 4th, 5th, and 6th EU Anti-Money Laundering Directives (4AMLD, 5AMLD, 6AMLD).
Our Approach
Eqwire’s AML/CTF measures are built on transparency, vigilance, and adherence to regulatory requirements. We aim to:
Prevent the misuse of our services for financial crime.
Protect our customers and stakeholders from financial crime risks.
Detect and report any suspicious activities to the appropriate authorities.
Ensure compliance with the highest regulatory standards.
Through these measures, Eqwire underscores its commitment to maintaining a secure financial ecosystem for individuals and businesses alike. For further inquiries or concerns, please contact our compliance team at [email protected].
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