Last updated: November 22, 2021

 

POLICY STATEMENT

          The Ample Rich Investor Corporation Limited (hereinafter “the Company”) subject to AML and CFT legislation in Thailand,  is committed to fully comply with all applicable laws and regulations regarding anti-money laundering procedures. The Company has adopted and will enforce the provisions set forth in the AML/CFT Policy in order to prevent money laundering and terrorist financing and other illegal activities arising from or in connection with the Company.

To ensure that the Company’s policies and procedures are adhered to, the Company shall designate an Anti-Money Laundering Compliance Officer (the "Compliance Officer"). The Compliance Officer is responsible for establishing and conducting Employee training programs to ensure that all appropriate Employees are aware of the applicable AML/CFT Laws and Regulations, the Company's AML/CFT Policies & Procedures and their responsibilities with respect to these policies.

1. OBJECTIVE

To set all the relevant rules and regulations, and prevent money laundering and terrorist financing and other illegal activities arising from or in connection with a criminal conduct.

2. DEFINITION

Money Laundering Money laundering is a process intended to mask the benefits derived from criminal conduct so that it appears to have originated from a legitimate source. Generally, the process of money laundering  comprises 3 stages:

  1. Placement: the physical disposal of the benefits of the criminal conduct.
  2. Layering: the separation of the benefits of the criminal conduct from their source by creating layers of financial transactions designed to disguise the audit trail.
  3. Integration:  the provision of apparent legitimacy to the benefits of criminal conduct. If the layering process succeeds, integration schemes place the laundered funds back into the economy so that they re-enter the financial system appearing to be a legitimate business Funds.

Terrorist Financing Terrorists require funds to carry out acts of terrorism and terrorist financing provides the funds needed. Sources of terrorist financing may be legitimate or illegitimate.

The methods used by terrorist organizations to move, collect, hide or make available funds for their activities remain similar to those used by the criminal organizations to launder their funds. The terrorist organization would have a similar concern to the typical criminal organization in laundering the funds in order to obscure or disguise the links between the organization and the funds.

Money laundering has many destructive consequences both for society as a whole and for those entities involved in money laundering activities. With respect to society as a whole, money laundering may provide resources for drug dealers, terrorists and other criminals to operate and expand their criminal activities.

Money laundering transactions may include:  

  1. Advising a potential or existing client on how to structure a transaction to avoid reporting and/or record keeping requirements;  
  2. Engaging in any activity while willfully or recklessly disregarding the source of the funds or the nature of the Client's transaction;  
  3. Engaging in any activity designed to hide the nature, location, source, ownership or control of the proceeds of criminal activity;  
  4. Dealing with funds to facilitate criminal activity; or  
  5. Dealing in the proceeds of criminal activity. Money laundering can involve the proceeds of drug dealings, terrorist activities, arms dealings, mail fraud, bank fraud, wire fraud or securities fraud, among other activities.

3. Methods of prevention

  1. KNOW YOUR CUSTOMER (KYC) / CUSTOMER DUE DILIGENCE (CDD)
  • To exercise due diligence when dealing with the customers, the person acting on behalf and beneficial owner.
  • To identify and verify the identity of customers and obtain satisfactory evidence of their identity and legal existence prior to opening of their trading accounts.
  • All trading account must be opened directly by the account holders. The company does not allow a third party to establish trading accounts for the account holders.
  • The company does not open or maintain anonymous accounts or account under fictitious names.

  1. AML/CFT RISK ASSESSMENT
  • All relationships shall be categorized with respect to their risk levels i.e. High, Medium and Low based on the risk profiling of customer through KYC/CDD application and as guided in the operational Manual for making effective decisions whether to perform Simplified Due Diligence (SDD) or Enhanced Due Diligence (EDD) or both at the time of opening and ongoing monitoring of business relationship.  

     3. MONITORING / REPORT

  • The Company shall perform such CDD measures as may be appropriate to its existing customers having regard to its own assessment of materiality and risk but without compromise on the identification and verification requirements.The Compliance Officer shall coordinate a periodic review of the Company's existing Client list, and ensure the adequacy of due diligence performed on existing Clients. In addition, the Company's policies, procedures, and controls may provide for the detection of suspicious activity, and if detected may require further review to determine whether the activity is suspicious, The Company requires any Employee who detects suspicious activity or has reason to believe that suspicious activity is taking place immediately to inform his or her immediate supervisor as well as the Compliance Officer. Under no circumstances may an Employee discuss the suspicious activity, or the fact that it has been referred to the Compliance Officer, with the Client concerned (Required by Law).The Compliance Officer shall determine in consultation with the higher management whether to report to the appropriate law enforcement officials any suspicious activity of which he becomes aware within 7 working days of knowing the suspicious activity (Required by Law). All the employees of the Company are strictly prohibited to disclose the fact to the customer or any other quarter that a suspicious transaction or related information that is being or has been reported to any authority, except if required by law.

     4. RECORDS RETENTION

  • Copies of all documents related to the Company's Client Identification Procedures will be retained for an appropriate period of time and, at a minimum, the period of time required by applicable law or regulation.The documents retain are copies of documents reviewed in connection with Client Identification Procedures or enhanced due diligence procedures, Client identification checklists, if any, or similar due diligence documentation, and any other documents required to be retained by applicable anti-money laundering legislation.The Company will retain documents for so long as a Client is a client of the Company and for a minimum of time required by applicable law or regulation after this relationship ends.
  • The Company shall, however, retain those records for longer periods where transactions, customers or accounts involved litigation or it is required by a court or other competent Authority.
  • The Company shall satisfy, on a timely basis, any inquiry or order from the relevant competent authorities, including Law enforcement agencies for the supply of information and records as per law.

    5. TRAINING

  • As part of the Company's AML/CFT program, all Employees are expected to be fully aware of the Company's AML/CFT policy and procedures.
  • Each Employee is required to read and comply with this Compliance policy and procedures, address concerns to the Compliance Officer and sign the acknowledgement form confirming that he/she has read and understands the Company's AML/CFT policy and procedures.
  • To ensure the continued adherence to the Company’s AML/CFT policy and procedures, all Employees are required to reconfirm their awareness of the contents of this document by signing the acknowledgement form annually, or more frequently, as required by the Compliance Officer.