What is Money Laundering?

Money laundering is the process by which criminally obtained money or other assets (criminal property) are exchanged for “clean” money or other assets with no obvious link to their criminal origins. Criminal property may take any form, including money or money’s worth, securities, tangible property, and intangible property. It also covers money, which is used to fund terrorism.

Money laundering activity includes:

  • Acquiring, using, or possessing criminal property

  • Handling the proceeds of crimes such as theft, fraud, and tax evasion

  • Being knowingly involved in any way with criminal or terrorist property

  • Entering arrangements to facilitate laundering criminal or terrorist property

  • Investing the proceeds of crimes in other financial products

  • Investing the proceeds of crimes through the acquisition of property/assets

  • Transferring criminal property.

There is no single stage of money laundering; methods can range from the purchase and resale of luxury items such as a car or jewelry to passing money through a complex web of legitimate operations. Usually, the starting point will be cash, but it is important to appreciate that money laundering is defined in terms of criminal property. This can be property in any conceivable legal form, whether money, rights, real estate, or any other benefits, if you know or suspect that it was obtained either directly or indirectly, as a result of criminal activity and you do not speak up then you too are taking a part in the process.

The money laundering process follows three stages:

  1. Placement: Disposal of the initial proceeds derived from illegal activity e.g. into a bank account.

  2. Layering: The money is moved through the system in a series of financial transactions to disguise the origin of the cash to give it the appearance of legitimacy.

  3. Integration: Criminals are free to use the money as they choose once it has been removed from the system as apparently “clean” funds. No financial sector business is immune from the activities of criminals and firms should consider the money laundering risks posed by the products and services they offer.

Policy

It is the policy of Seven Capitals Foreign Brokerage Limited Market Limited to actively pursue the prevention of money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities. Seven Capitals Market Limited is committed to AML compliance following applicable law and requires its officers, employees, and appointed producers to adhere to these standards in preventing the use of its products and services for money laundering purposes.

For the policy, money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the unlawful proceeds appear to have been derived from legitimate origins or constitute legitimate assets.

Key Principle

2.1 All of the Company’s employees are required to read and acknowledge the Anti- Money Laundering Manual of the Company and shall at all times act under the ‘Key Principles’ set out therein.

(a) Take appropriate steps to protect the Company and its domain from any activities which involve money laundering and terrorist financing.

(b) The Company must maintain and implement written policies and procedures concerning combating money laundering a system of internal controls to ensure ongoing compliance with applicable laws which shall be reviewed and monitored by a designated person and to take appropriate action once suspicious activity is detected through the reporting of such transactions in line with the guidelines set out by Global Anti – Money Laundering regulations.

(c) Comply with applicable anti-money laundering and terrorist financing laws and regulations as established by the Global Anti- Money Laundering guidelines.

(d) All business units of the Company shall follow the AML policies and procedures.

(e) Report all identified suspicious activities to the extent that it can do so under all applicable foreign and domestic laws.

(f) Compliance with the Company’s AML policies will be monitored through a combination of internal audit and regulatory reviews of compliance with relevant anti-money laundering legislation and/or regulations.

(g) Retaining all the customer-related documents for a period specified as per the Financial Services Authority St. Vincent.

(h) The Company does not offer services of opening anonymous accounts.

(i) Full cooperation with law enforcement and regulatory agencies to the extent that it can do so under all applicable laws.

(j) Train staff on Know Your Customer and Anti-Money Laundering policies and new AML laws and regulations.​

(k) The AML Compliance Committee is responsible for initiating Suspicious Activity Reports (“SARs”) or other required reporting to the appropriate law enforcement or regulatory agencies.

Any contacts by law enforcement or regulatory agencies related to the Policy shall be directed to the AML Compliance Committee.

The committee shall

  • Receive internal reports of (suspicions of) money laundering

  • Investigate reports of suspicious events

  • Make reports of relevant suspicious events to the relevant authorities

  • Ensure the adequacy of arrangements made for the awareness and training of staff and advisers

  • Report at least annually to the firm’s governing body on the operation and effectiveness of the firm’s systems and controls.

  • Monitor the day-to-day operation of anti-money laundering policies concerning: the development of new products; the taking on of new customers; and changes in the firm’s business profile.

Introduction

1.1. Seven Capitals Foreign Brokerage Limited: Registered Addresses- Headquarter: Level-6 Ken Lee Building, 20 Edith Cavell Street, Port Luis 11302, Mauritius. Marketing Office: 403, API World Tower, Sheikh Zayed Road, World Trade Center 1, Dubai UAE. P.O Box-47425 We are authorized and regulated by the Financial Services Commission as An Investment Broker in Global Business with the License/registration No. GB 21026349.

The Company is authorized as a Business Company under the Business Companies (Amendment and Consolidation) Act, in Dubai (herein the “Law”).

1.2. The objects of the Company are all subject matters not forbidden by Business Companies (Amendment and Consolidation) Act in Dubai (herein the “Law”), in particular, but not exclusively all commercial, financial, lending, borrowing, trading, service activities and the participation in other enterprises as well as to provide brokerage, training and managed account services in currencies, commodities, indexes, CFDs and leveraged financial instruments.

1.3. The Company is committed to combating money laundering and for this reason, it has appointed a dedicated Anti-Money Laundering Compliance Officer (the “AMLCO”) who is accountable to the Board of Directors and Senior Management of the Company.

The AMLCO is further responsible for the training of employees concerning the Anti-Money Laundering Law and any amendments thereof as well as for the preparation of the internal procedures of the Company.

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