Hub Remit is always committed to fight against money laundering. For this very reason, we have implemented AML/CFT Policy. We are also committed to continually observe the Anti Money Laundering requirements by providing our foreign correspondent banks and agents due-diligence information on transactions in line with the guidelines and recommendations of the Financial Action Task Force (FATF) as and when required. We bear the responsibility to establishment of such programs and ensure that its permitted services are not being used to launder unlawfully derived funds or to finance terrorist acts.
Terms and their Definitions
Money Laundering (ML):
Money Laundering is the process whereby proceeds of crimes such as drug trafficking, smuggling (alcohol, arms), kidnapping, gambling, robbery, counterfeiting, bogus invoicing, tax evasion, misappropriation of public funds and the like are converted into legitimate money through a series of financial transactions making it impossible to trace back the origin of funds. Conversion of this unofficial or black money into official currency thereby ‘changing its colour’ is called as money laundering.
Section 2 of “Asset (Money) Laundering Prevention Act, 2008 has referred Money Laundering to any of the following acts:
An act committed by any person who, in any manner, directly or indirectly, and willingly, provided or collects funds, support, or attempts to do so, in order to use them or knowing that these funds will be used in whole or in part for the execution of a terrorist act, or by a terrorist or terrorist organization.
Scope & Applicability
Objective of the Policy
The major objectives of the policy are:
Money Laundering Process
Documentation & Confidentiality
All records including customer’s identification documents and related data are maintained and retained for minimum of 6 years with almost care for further reference and audit trail. All customer and transactional information are kept confidential. Internal Audit is done to test the compliance. All findings and observations are discussed with compliance department and reported to the Managing Director. Hub Remit is always committed to continually fulfill its Anti-Money Laundering obligations at all times.
Employee Due Diligence Procedures
The employee due diligence procedures are applied upon hiring the employee and throughout the course of employment. Hub Remit establishes an employee assessment system that is commensurate with the size of operations and risk exposure of the institutions to ML/TF. The employee assessment system shall include an evaluation of an employee’s personal information, including criminal records, employment and financial history.
Employee Training and Awareness Programs
The Company conducts awareness and training programs on AML/CFT practices and measures for their employees. Such training is conducted regularly and supplemented with refresher trainings.
KYC and CDD
Hub Remit is aware that availability of sufficient information underpins all other AML procedures and should be seen as a critical element in the effective management of ML risks.
The KYC & CDD Process are as follows:
Customer Identification Requirements
Customer Identification requires identifying the customer and verifying his/her identity by using reliable, independent source documents, data or information. Thus, the first requirement of Customer Identification Procedures (CIP) to be satisfied is that a prospective customer is actually who he/she claims to be. The second requirement of CIP is to ensure that sufficient information is obtained on the identify and the purpose of the intended nature of the remittance relationship. While verifying KYC documents, care should be exercised to ensure that any one photo Identification documents like Certificate of Citizenship, Passport and visa, Identity Card disclosing nationality are used to identify the customer.
Appointment of Compliance Officer
Hub Remit will have a Compliance Department under the purview of Head Compliance/ AML Compliance Officer who will look after the overall compliance of AML/CFT policies and procedures, with direct reporting to the Board. Also, he provides training to the employees and makes them aware about the new trends in AML/CFT.
Reporting to Regulatory Authorities