Reporting Procedure
• When an employee suspects or has a reason to suspect that funds proceed of "unlawful activity" or "serious offence"; and/or • When an employee suspects or has a reason to suspect that funds are linked, or related to, or used for terrorism, terrorist acts or by terrorist organizations or those who finance terrorism.
• The employees will inform the MLRO. • MLRO will evaluate and investigate the suspicious transaction
• If yes, MLRO completes his suspicious transaction report. • Involve the responsible authority for that issue.
" M.I.D. House of diamonds.” " will not notify any person involved in the transaction that the transaction has been reported. We will maintain all supporting documentation as confidential. The MLRO will be responsible for ensuring that any records are maintained properly and that suspicious transaction reports are filed as required. Copies of any suspicious transactions report and any supporting documents will be maintained for six years from the date of filing the suspicious transaction report. All the records will be stored securely and will be capable of being retrieved without undue delay. " M.I.D. House of diamonds.” " Training Programmers • If an employee becomes suspicious of a particular customer or transaction, they must report the matter to the managers. • That an employee does not have to be certain, only suspicious that the transaction(s) relate to criminal activity; • If an employee has suspicions and fails to report them they may be committing a criminal offense and/or be liable to disciplinary action for gross misconduct. • That an employee should not investigate the customer or the transaction(s) unless advised by the management/MLRO to do so, nor should they inform the customer of their suspicion; • That, unless they are instructed otherwise, they should continue to deal with the customer in the normal way.
Our training will occur on at least an annual basis, with a different focus for new staff, front – line staff, and compliance staff. The training will include:
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