We are committed to complying with all relevant legislation and regulation across the jurisdictions in which we operate. Accordingly we have developed a policy of constructive engagement and cooperation with all authorities charged with anti-financial crime responsibilities and our policy includes structures, processes and procedures which are designed to prevent and detect financial crime.

Risk Assessment

We adopt a risk-based approach to our business so we can best focus our resources in the areas where they are most needed. In doing this we take account of a number of factors including the type of client concerned, the nature of the products to be used and the distribution channel.

Know Your Customer, Investigation and Reporting

We have processes designed to verify our clients' identities using a variety of methods and technologies. Unusual or suspicious transactions are investigated by a team of experienced independent investigators and reports are made to local law enforcement authorities as required. We maintain records of clients and transactions for as long as required by local legislation.

While all our management and staff have an obligation to follow our policy, we also have a global network of Money Laundering Reporting Officers whose job is to provide on the spot advice and guidance on financial crime issues, as well as work with the authorities on specific cases.  

Staff training

Staff are trained in how to spot red flags relating to financial crime and how to report it. We use a variety of methods, including web-based tools, to ensure that training is as comprehensive and up-to-date as we can make it.

Cash

We do not accept cash receipts or make cash payments under any circumstances.