AML / CFP Policy – Bernardex

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AML / CFP Policy

In an aim to protect its clients from money spinning and the financing of terrorism, Bernardex acts in accordance with the guidelines of the Committee of Experts on the Evaluation of Anti-Money Laundering Measures and the Financing of Terrorism – MONEYVAL. This pan-European monitoring body with 47 member states, reports directly to its principal organ – the Committee of Ministers of the Council of Europe. MONEYVAL appraises compliance with the principal international standards to counter money laundering and the financing of terrorism. It also judges the effectiveness of their implementation, and presents recommendations to national authorities regarding necessary improvements to their systems. Furthermore, MONEYVAL conducts typology research of money laundering and terrorist financing methods, trends and techniques. The organization was originally an observer to the FATF before becoming an associate member as of June 2006. Therefore, Bernardex has implemented procedures to prevent people from laundering money.

THESE POLICIES INVOLVE:

Making sure that clients have valid proof of identification and maintaining records of identification information
Verifying that clients aren’t terrorists nor suspects by examining the lists of known or suspected terrorists.
Notifying clients that the information they provide may be used to verify their identity.
Supervising the clients’ money transactions.
Dismissing cash, money orders, third-party transactions, exchange houses transfers or Western Union transfers. Money laundering occurs when illegal/criminal activity funds are changed to make it seem as if these funds have come from legitimate sources.

HOW MONEY IS NORMALLY LAUNDERED:

PLACEMENT STAGE

Cash or cash equivalents are first moved into other accounts (e.g. futures accounts) via financial institutions, instruments through a series of financial transactions designed to hide the origin of the money (e.g. executing trades with little or no financial risk or transferring account balances to other accounts).

LAYERING STAGE

In the second stage is “layering” aka “structuring stage”. Funds are broken down into small transactions, making it difficult to detect the laundering activity. In the modern world, the funds can also be used for trading in different stocks or currencies across different markets. Another common way that criminals use to cover the trail is buying assets with the cash and selling them. Assets can be re-sold locally or abroad and hence makes it harder to trace and thus seize.

INTEGRATION STAGE

Integration stage is the final stage of money laundering, in which the money is now returned to the criminals legitimately (e.g. closing a futures account and transferring the funds to a bank account).

Seeing that trading accounts are one of the vehicles that may be used to spin unlawful funds or to conceal the true owner ( by executing financial transactions that obscure the origins of the fund), Bernardex directs funds withdrawals back to their original source. These guidelines have been implemented to protect Bernardex and its clients, as International Anti-Money Laundering requires financial services institutions to be aware of potential money laundering abuses that could occur in a customer account and implement a compliance program to deter, detect and report potential suspicious activity. For questions/comments regarding these instructions, please contact us at [email protected]