FibbPay establishes and implements adequate and appropriate policies, procedures and controls taking into account factors, takes all measures to ensure that proper safeguards exist to mitigate the risks and to prevent a contravention of any requirement under the Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Ordinance include the following:
Take enhanced KYC measures to manage those customers with higher risks and knows that simplified measures may be applied to customers with lower risks;
Appoint a Compliance Officer (CO) to act as a focal point for the oversight of all activities;
Appoint a Money Laundering Reporting Officer (MLRO) as a central reference point for reporting suspicious transactions;
Provides training to all relevant staff (including new staff) in order to ensure they are made aware of the AMLO and adopting appropriate measures letting frontline staff know the responsible areas and to judge whether a transaction is suspicious;
Adopt a risk-based approach to adopt appropriate controls and oversight and accordingly to determine the extent of due diligence to be performed and the level of ongoing monitoring to be applied;
Keep the documents obtained in the course of identifying and verifying the identity of the customer and the documents obtained in connection with the transactions shall be kept throughout the business relationship with customer and for a period of six years after the end of the business relationship;
Keep the policies and procedures under regular review and assesses that the risk mitigation procedures and controls are working effectively; FibbPay will NOT do business with anyone suspected of or directly involved in Money Laundering or where funds have been sourced by any illegal activity.
