Anti-Money Laundering (AML) Policy

Last Updated: 28th August 2024

1. Introduction

Mellent Consulting ("we," "our," "us") is committed to preventing money laundering and terrorist financing in all aspects of our business. This Anti-Money Laundering (AML) Policy outlines the procedures and responsibilities for ensuring compliance with applicable AML laws and regulations.

2. Purpose

The purpose of this AML Policy is to ensure that Mellent Consulting detects and deters money laundering and terrorist financing activities, complies with all applicable AML laws and regulations, and implements effective controls and procedures to mitigate the risks associated with money laundering.

3. Scope

This policy applies to all employees, contractors, and agents of Mellent Consulting. It covers all services and activities, including client onboarding, transaction processing, and ongoing monitoring.

4. Key Definitions

Money Laundering: The process of disguising the origins of illegally obtained money.

Terrorist Financing: The provision of funds or financial support to individual terrorists or terrorist organizations.

Customer Due Diligence (CDD): The process of verifying the identity of our clients and assessing the risks associated with each client.

5. Roles and Responsibilities

5.1 Compliance Officer

The Compliance Officer is responsible for overseeing the implementation of this AML Policy, ensuring compliance with AML laws, monitoring transactions, and reporting suspicious activities.

5.2 Employees

All employees must be familiar with this AML Policy, report suspicious activities, and participate in AML training as required.

6. Customer Due Diligence (CDD)

6.1 Identification

We will perform Customer Due Diligence to verify the identity of our clients, collecting necessary information and verifying it using reliable, independent sources.

6.2 Risk Assessment

Each client will be assessed for the risk of money laundering and terrorist financing. High-risk clients may require enhanced due diligence (EDD).

7. Record Keeping

We will maintain records of all CDD information, transactions, and reports of suspicious activities for a minimum of [X] years or as required by law.

8. Reporting Suspicious Activities

Any employee who identifies or suspects money laundering or terrorist financing must report their suspicions to the Compliance Officer immediately. The Compliance Officer will evaluate and, if necessary, file a Suspicious Activity Report (SAR).

9. Training and Awareness

All employees will receive regular AML training, covering the risks of money laundering, identifying suspicious activities, and understanding legal obligations.

10. Monitoring and Auditing

We will regularly monitor and audit our AML compliance efforts to ensure the effectiveness of our policies and procedures.

11. Non-Compliance and Disciplinary Actions

Failure to comply with this AML Policy may result in disciplinary action, up to and including termination of employment or contract.

12. Policy Review

This AML Policy will be reviewed and updated at least annually or as required by changes in relevant laws and regulations.

13. Contact Information

If you have any questions or concerns regarding this AML Policy, please contact:

Email: compliance@consulting.mellent.com
Mellent Consulting