The “Anti-Money Laundering & Counter Terrorist Financing Policy” is a global policy that is designed to ensure that all companies with the Diginex group (“Diginex”) comply with the requirements and obligations set out by all applicable laws, regulations and regulatory guidance.

In order to protect its reputation, customers and employees, it is essential that Diginex minimizes the risk of being used to facilitate money laundering and terrorist financing. Diginex considers the FATF designated categories of offences in its definition of money laundering.

The Policy applies to all the countries in which the group operates and to all business activities within those countries.

As a group, Diginex will:

(i)  Establish clear lines of internal accountability, responsibility and reporting. All business areas must ensure that appropriate internal controls are in place and operating effectively, with regular reporting group senior management.

(ii)  Establish internal AML / CFT policies, procedures, systems and controls which interpret Diginex standards;

(iii)  Establish and maintain a Risk Based Approach (“RBA”) towards assessing and managing the money laundering and terrorist financing risk to Diginex;

(iv)  Establish appropriate processes to identify the client and where appropriate the beneficial owner(s). This also includes obtaining additional information and documentation according to the RBA, identifying Politically Exposed Persons, determining source of funds / wealth, and name and transaction screening;

(v)  Establish adequate on-going and transaction monitoring processes to keep client records up-to-date and identify any suspicious activity. This includes an appropriate degree of automation;

(vi)  Maintain a high level of awareness to sanctions and embargo related matters;

(vii) Establish strong processes to refuse and / or report any suspicious transaction related to the proceeds of crime or to be used for an illegal activity such as terrorism;

(viii) Define appropriate internal channels to make prompt reports on unusual behaviour and, where applicable to report suspicious activity and / or transactions to relevant regulatory and law enforcement authorities;

(ix) Provide regular, risk-based AML / CFT training to all employees, with training records being kept as required by law;

(x) Maintain client records for a minimum of five years. This includes records of identification, account opening, and transactions;

(xi) Undertake regular checks of client due diligence files to ensure compliance with the AML / CFT framework;

(xii) Review the AML / CFT program annually to ensure it is still consistent with applicable regulations;

(xiii) Work regulators, law enforcement agencies and international bodies in their efforts to combat the use of the financial system for the laundering of the proceeds of crime and the movement of funds for criminal purpose

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