Effective Date: 05/04/2025
Approved By: Sandarv Comodities Pvt Ltd
Review Date: 05/05/2025
1. Introduction
This Anti-Money Laundering (AML) Policy outlines the commitment of Sandarv Comodities Pvt Ltd to prevent, detect, and report any activities related to money laundering, terrorist financing, and other financial crimes. The Company is committed to maintaining the highest standards of integrity, transparency, and compliance with all applicable AML laws and regulations.
2. Scope
This policy applies to all employees, officers, directors, contractors, and third-party service providers of Sandarv Comodities Pvt Ltd, irrespective of their location.
3. Regulatory Framework
Sandarv Comodities Pvt Ltd will comply with all relevant AML laws, regulations, and guidelines, including but not limited to:
The [Insert Jurisdiction] Anti-Money Laundering Act
The Financial Action Task Force (FATF) Recommendations
The Bank Secrecy Act (if applicable)
Other applicable local and international laws
4. Definitions
Money Laundering: The process of concealing the origins of illegally obtained money.
Terrorist Financing: Providing funds to support terrorist activities, regardless of the source.
Politically Exposed Persons (PEPs): Individuals holding prominent public positions.
5. AML Program Objectives
Prevent the use of Sandarv Comodities Pvt Ltd services for money laundering and terrorist financing.
Detect and report suspicious activities.
Ensure compliance with legal and regulatory requirements.
Train employees to recognize and respond to AML risks.
6. Customer Due Diligence (CDD)
The Company will implement CDD procedures, including:
Know Your Customer (KYC): Verification of customer identity through reliable documents.
Risk Assessment: Assessing the risk level of customers based on factors like geography, occupation, and transaction patterns.
Ongoing Monitoring: Continuous review of transactions to identify unusual or suspicious activity.
7. Suspicious Activity Reporting
All employees must report any suspicious activity immediately to the designated AML Compliance Officer (AMLCO) or through the company's reporting channels. The AMLCO will assess the report and decide if further action, such as filing a Suspicious Activity Report (SAR), is necessary.
8. AML Compliance Officer (AMLCO)
The Company will appoint an AMLCO responsible for:
Implementing and maintaining the AML program.
Providing AML training to employees.
Serving as the point of contact for regulatory authorities.
9. Training and Awareness
All employees will undergo regular AML training, covering:
The importance of AML compliance.
Identifying red flags of money laundering and terrorist financing.
Reporting procedures.
10. Record-Keeping
The Company will maintain comprehensive records of:
Customer identification documents.
Transaction records.
Suspicious activity reports and related communications.
These records will be retained for a minimum of 3 years or as required by law.
11. Internal Controls and Audits
The Company will implement internal controls to prevent and detect AML risks, including periodic audits to evaluate the effectiveness of the AML program.
12. Non-Compliance and Disciplinary Actions
Failure to comply with this policy may result in disciplinary action, including termination of employment, legal action, and regulatory penalties.
13. Policy Review and Updates
This policy will be reviewed annually or as needed to reflect changes in laws, regulations, or business activities.
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