AML Policy

CRAND’s Anti-Money Laundering and Know Your Customer Policy (AML/KYC Policy) is designed to prevent and mitigate possible risks of CRAND being used as a channel to launder money, finance terrorism or take part in other illegal activities.  

 International and local regulations require CRAND to implement effective internal procedures and mechanisms to prevent money laundering, terrorism financing, narcotics and human trafficking, proliferation of weapons, corruption and bribery and take action in case of any form of suspicious activity from its Users.

 

Our AML/KYC Policy covers the following:

  • Verification Procedures 

CRAND has formulated and implemented its own internal procedures for verification within the ambit of applicable AML/KYC frameworks. Verification procedures are further classified into two below: 

Identity Verification

CRAND's identity verification procedure requires the user to provide us with reliable, independent source documents, data or information (e.g. national ID card, passport data page, voters card, utility bill etc.) 

CRAND will take further steps to confirm the documents and information provided by users and reserves the right to investigate and report users who have been identified as carrying out suspicious activities and transactions to regulatory authorities.  

CRAND shall on an on-going basis verify its users' identity especially when information has been updated or activity appears suspicious. CRAND reserves the right to request up-to-date documents from its users.

Users' identification information will be collected, stored, shared and protected strictly in accordance with CRAND's Privacy Policy and similar regulations.

Card verification

Users who intend to use debit or credit cards in connection with CRAND's services have to pass card verification in accordance with instructions available on the CRAND website.

  • Compliance Officer

The Compliance Officer(s) are individual(s) authorised by CRAND to ensure effective implementation and enforcement of the AML/KYC Policy. It is the compliance officer’s responsibility to supervise all aspects of CRAND'S AML/KYC policy including but not limited to:

  1. Collecting Users’ Identification Information

  2. Monitoring transactions and investigating any significant deviations from normal activity.

  3. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations.

  4. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs.

  5. Updating risk assessment regularly.

  6. Providing law enforcement with information as required under the applicable laws and regulations to prevent money laundering, terrorist financing and other illegal activity.

The above list is not exhaustive and the Compliance Officer will monitor users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.

  1. Monitoring Transactions

Users are known not only by verification of their identity but also by analyzing transactional patterns. Therefore, CRAND relies on data analysis as a risk-assessment and suspicion detection tool. Some of the system functionalities in place to monitor transactions are:

 

  1. Regular check of users against recognized “blacklists” (e.g Law enforcement Notices).

  2. Placing users on watch and service denial lists.

  3. Opening cases for investigation where need be.

  4. Sending internal communications and filling out statutory reports.

  5. Case and document management.

  6. Ensure that transactions of suspicious nature are reported to the proper law enforcement agencies.

  7. Request users to provide any additional information and documents in case of suspicious transactions.

  8. Suspend or terminate a user’s account when CRAND has reasonable suspicion that such user engaged in illegal activity.

  1. Risk Assessment

CRAND, in line with global requirements and standards, has adopted a risk-based approach to combating money laundering, terrorist financing and other illegal activities. By adopting a risk-based approach, CRAND is able to ensure that measures to prevent or mitigate money laundering, terrorist financing and other illegal activities are commensurate to the identified risks. 

The risk-based approach, allows resources to be allocated in the most efficient ways. That is, resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.