Anti Money Laundering (AML) Policy

  

1. INTRODUCTION

At Feggeri, we are committed to maintaining the highest ethical standards and complying with all applicable laws and regulations, including those related to anti-money laundering (AML) and combating the financing of terrorism (CFT). This policy outlines our approach to prevent money laundering and the steps we take to ensure the integrity of our business operations.

 

2. RISK ASSESSMENT

We conduct a comprehensive risk assessment to identify and evaluate potential money laundering risks specific to our jewellery business. This assessment helps us understand our vulnerabilities and implement appropriate control measures to mitigate those risks effectively.

 

3. CUSTOMER DUE DILIGENCE (CDD)

To prevent money laundering, we implement a customer due diligence process, including:
a. Customer Identification: We verify the identity of our customers through reliable and independent sources, such as government-issued identification documents and databases, ensuring accurate and up-to-date information.

1. Enhanced Due Diligence (EDD): In cases where higher risks are identified, such as large transactions or customers from high-risk jurisdictions, we perform enhanced due diligence, gathering additional information to ascertain the legitimacy of the customer and transaction.
2. Politically Exposed Persons (PEPs): We exercise enhanced scrutiny when engaging with individuals who hold prominent public positions or are closely associated with such individuals, in line with local regulations and international standards.

 

4. MONITORING AND REPORTING

We employ transaction monitoring systems and analytics to detect unusual or suspicious activities that may indicate potential money laundering. Our dedicated AML team continuously reviews and analyses these alerts to ensure prompt action and reporting of suspicious transactions to the relevant authorities, as required by law.

 

5. TRAINING AND AWARENESS

We provide regular training sessions to our employees to raise awareness about money laundering risks and the importance of complying with AML/CFT regulations. Our staff members are equipped with the necessary knowledge and tools to identify and report any suspicious activities promptly.

 

6. RECORD-KEEPING

We maintain comprehensive records of customer transactions, identification documents, and due diligence documentation for the prescribed period, as mandated by applicable regulations. This ensures that we have a trail of information readily available for regulatory inquiries or investigations.

 

7. COMPLIANCE OVERSIGHT

We assign a dedicated compliance officer responsible for overseeing the implementation of our AML/CFT policies and ensuring adherence to relevant laws and regulations. The compliance officer regularly reviews and updates our AML program to address emerging risks and changing regulatory requirements.

 

8. REPORTING AND COOPERATION

Feggeri is committed to cooperating with regulatory authorities and law enforcement agencies. We promptly report any suspicious transactions or activities to the relevant authorities and provide full support during investigations as required by law.

 

9. CONTINUOUS IMPROVEMENT

We regularly evaluate the effectiveness of our AML policies, procedures, and controls, seeking opportunities for improvement. We remain vigilant in monitoring new money laundering trends and technological advancements to enhance our ability to combat illicit activities.

 

10. WHISTLEBLOWER PROTECTION

We maintain a whistleblowing mechanism that allows our employees and stakeholders to report concerns related to money laundering or any violations of our AML policies. We ensure the confidentiality and protection of whistleblowers in line with legal requirements.

 

11. PENALTIES FOR NON-COMPLIANCE

Non-compliance with this AML policy may result in disciplinary action, including termination of employment or legal action, as deemed appropriate based on the severity of the violation.

 

This AML policy is integral to our commitment to maintain the integrity of our business operations, protect our stakeholders, and contribute to the global efforts in combating money laundering and the financing of terrorism.