Copernicus Gold Singapore Pte. Ltd. (hereinafter - “the Company”) protects itself from involvement in money laundering or suspicious activity by the following:
- Performing a risk assessment to determine the risk profile of the Company
- Establishing AML policies and procedures
- Implementing internal controls throughout its operations that are designed to mitigate risks of money laundering
- Implementing anti-bribery policy
- Performing know your customer (“KYC”) procedures
- Designating a Compliance Officer with full responsibility for the AML Program
- Conducting regular AML audit
- Providing regular AML training to relevant employees
POLICIES AND PROCEDURES
The Policy has been developed with an assistance of a reputable compliance solutions provider and approved by the Company’s Board. The Policy approved has been provided to all relevant employees. All policies and procedures will be reviewed and updated or revised as needed, but no less often than annually.
The Company has developed and implemented internal controls for the purpose of ensuring that all of its operations comply with all AML legal requirements and that all required reports are made on a timely basis. Some of those internal controls are listed within this document and include, but are not limited to, the Anti-bribery policy, Transaction monitoring policy, KYC procedures, and the required reports on the Program’s effectiveness to the Board.
All of the relevant officers and employees of the Company are required to receive AML and anti-bribery training at least annually. New employees will receive appropriate training within 30 days of their hire date. Training for all employees includes not only the legal elements of AML laws and regulations but also covers job specific applications of these laws. Ongoing training is provided and updated regularly to reflect current developments and changes to laws and regulations.
It is the Company’s policy to ensure that it has reasonably identified each customer who uses the Company’s platform. Users may be identified using a variety of methods.
ACCOUNT OPENING PROCEDURES
Additionally, the Company, as part of its account-opening process: (i) cross-checks the names of users against compliance databases such as the OFAC Specially Designated Nationals list and other governmental watch lists; (ii) requires users to provide proof of identification; and (iii) does not permit any payment above 250 Singapore dollars to be made with incomplete account-opening information.
Documents used in opening an account relationship must be verified prior to establishing the account. Verification of identity will require multi-factor authentication, layered security and other controls to ensure a meaningful user identity confirmation process based on account size or other factors.
SUSPICIOUS TRANSACTION AND ACTIVITY REPORTS
The Company diligently monitor transactions for suspicious activity. Transactions that are unusual are carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Internal controls have been implemented so that an ongoing monitoring system is in place to detect such activity as it occurs.
The Company is responsible for directing the annual AML audit of the Company’s operations.