Declaration regarding AML, CTF and KYC within Thomas-Walther Limited
Thomas-Walther has made it a priority to combat and prevent money laundering and terrorist financing through our Company. Thomas-Walther prides itself of being able to identify and understand risks of money laundering and terrorist financing in order to apply preventive measures through its Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) policies and procedures, which are in line with the Financial Action Task Force on money laundering (FATF) and international standards.
In light of our changing environment, Thomas-Walther continually evaluates the strength and relevance of its existing policies, procedures and employee training programs and, if necessary, updates them to address these changes.
Below is a summary of what Thomas-Walther AML and CTF policies and procedures include:
- Thomas-Walther has a legal and regulatory compliance program that includes a designated officer that is responsible for coordinating and overseeing the AML framework.
- Proper Know-Your-Client (KYC) practices are central, and the knowledge of the client provides a basis for understanding the general activities in which a client usually would be expected to engage.
- Thomas-Walther developed written policies documenting the processes in place to prevent, detect and report suspicious transactions.
- In addition to welcoming inspections by government supervisors/regulators, Thomas-Walthers’ internal audit and external auditors assess AML policies and practices on a regular basis.
- Thomas-Walther has a policy prohibiting accounts/relationships with shell banks.
- Thomas-Walther has policies covering relationships with Politically Exposed Persons (PEP), their family and close associates.
- Thomas-Walther has a risk-based assessment of its client base and their transactions.
All clients are screened against the Special Investigation Commission (SIC) list, and international lists on Complinet:
- Sanctions List (including but not limited to Service d’Information et de Contrôle sur les Circuits Financiers; European Union; HM Treasury (formally Bank of England); Office of Foreign Assets Control (OFAC), United States; United Nations Security Council Committee; US Department of State.)
- Law Enforcement Lists (including but not limited to City of London Police UK; Federal Investigation Agency; Federal Bureau of Investigation (FBI) United States; Interpol; National Crime Squad UK; Serious Organized Crime Agency; US Air Force Office of Special Investigations; US Drug Enforcement Administration; US Secret Service; Combined Forces Special Enforcement Unit-British Columbia (CFSEU-BC), Canada…)
- Regulatory Enforcement Lists (Asia/Pacific enforcement bodies; European enforcement bodies; North American enforcement bodies; Latin American/Caribbean enforcement bodies; UK enforcement bodies)
- Other Bodies (Companies House – Disqualified Directors; World Bank – Debarred Parties; Lloyd’s Register – Fairplay)
- High Profile Persons Data and Dow Jones Database for high-ranking government officials and PEP.
Thomas-Walther is fully informed of the laws and regulations governing its correspondents abroad and deals with them in compliance with such laws and regulations. Thomas-Walther is committed to abide by the laws, regulations, procedures, sanctions and restrictions adopted by international legal organizations and/or by the sovereign authorities in the correspondents’ home countries, including but not limited to, bills passed by the U.S. congress.
Thomas-Walther does not deal with or facilitate transactions or provide consultancy or facilitating services to entities designated as terrorist or criminal organizations by local authorities, international organizations and sovereign authorities in countries where it maintains correspondent accounts. Furthermore, Thomas-Walther does not deal with or facilitate transactions or provide consultancy or facilitating services to a person if it has any suspicion that this person is acting on behalf of, or is owned or controlled by such designated entities and refrains from facilitating transactions or provide consultancy or facilitating services if it suspects that such transactions or provide consultancy or facilitating services are linked to such designated entities or any criminal and/or terrorist activity.