Anti-Money Laundering And Anti-Financial Crime Policy
Skilled Migration Group Limited is committed to the highest standards of Anti-Money Laundering (AML) and Anti-Financial Crime (AFC) including Anti-Bribery and Corruption (ABC), Counter Terrorism Financing (CTF), Anti-Fraud and other punishable criminal acts.
Everyone, shareholder, manager, employee, and clients are required to adhere to these standards to protect Skilled Migration Group Limited against being misused for money laundering and/or terrorist financing or other illegal purposes.
Skilled Migration Group Limited adheres to all applicable laws and regulations in all countries where we have business relationships or conduct business in.
This Anti-Money Laundering and anti-financial crime policy addresses all AML related topics, including Know Your Customer (KYC), ABC, Sanctions & Embargoes and Anti-Fraud, and will be reviewed on an ongoing basis to continue to ensure compliance and manage risk at all times.
Business and Relationships that are prohibited
Skilled Migration Group Limited will refuse to enter into a relationship or accept any client, or will terminate a relationship or client’s business, if Skilled Migration Group Limited cannot form a reasonable belief that it knows the true identity of the client and/or UBO (ultimate beneficial owner). And/or the nature of business or formal requirements concerning the identification of the client and/or UBOs are not met.
Skilled Migration Group Limited will not Accept funds or assets that are known or suspected to be the proceeds of criminal activity.
Skilled Migration Group Limited will not enter into any business relationships with individuals or entities known or suspected to be a terrorist or a criminal organisation or member of such or listed on sanction lists.
Skilled Migration Group Limited will not open or maintain anonymous accounts, or pay-through accounts.
Skilled Migration Group Limited will not enter into relationships with clients from Special Risk Countries or enter into relationships with clients operating in prohibited industries.
Control and Management of AML and AFC Risk
Skilled Migration Group Limited has developed and implemented measures to identify, manage and control AML risk.
Including continuous review of transactions, checking for any evidence of any prohibited business relationships, not entering into or maintaining and transactions with companies or individuals from prohibited countries, and not accepting any cash Payments (including cash remittances) and all payments must be made by the contracted party (i.e. no payments are to be accepted from third parties).
Compliance with Embargos
Compliance with all applicable embargoes is mandatory by everyone at Skilled Migration Group Limited, shareholder, manager, employee and its contractors globally.
All embargo regulations are binding for the whole of Skilled Migration Group Limited.
Anti-Bribery and Corruption (ABC) and Anti-Fraud
Skilled Migration Group Limited does not condone, tolerate or accept bribery, or any form of corruption.
Everyone at Skilled Migration Group Limited, shareholder, manager, employee and its contractors globally are strictly prohibited from having any involvement in any acts of bribery and corruption.
Suspicious Activity Reports (SARs) and Suspicious Transaction Reports
Suspicious activities will be properly handled by Skilled Migration Group Limited, by reporting to the managing director or finance manager of the client in question. They in turn have a responsibility to report it to the CFO.
Ultimate Responsibility
The managing director is ultimately responsible for making sure that Skilled Migration Group Limited is fully compliant with this policy and all laws.
This Anti-Money Laundering and anti-financial crime policy was last updated on the 7th May 2024