1. Policy Statement and Commitment
WEN LTD is dedicated to preventing the misuse of its platform for money laundering, terrorist financing, or other illegal activities. Operating under the laws of Saint Lucia, the company is focused on maintaining ethical business practices while adhering to the Money Laundering (Prevention) Act and associated regulations. This policy outlines the steps WEN LTD takes to protect its reputation and ensure compliance with international financial standards.
2. Purpose and Objectives
This policy provides a clear framework for WEN LTD’s employees and partners to ensure compliance with Saint Lucian regulations for Designated Non-Financial Businesses and Professions (DNFBP).
The key objectives include:
- Establishing clear protocols regarding money laundering, terrorist financing, and the avoidance of sanctioned entities.
- Clearly outlining compliance responsibilities for all employees.
- Offering guidance to employees in their daily tasks in line with the Money Laundering (Prevention) Regulations.
- Promoting a workplace culture that values legal integrity and transparency.
3. Know Your Client (KYC) Procedures
WEN LTD adopts robust KYC procedures, collecting and verifying identification documents before onboarding any client.
- For Individuals: WEN LTD requests personal details including full name, date of birth, nationality, and residential address.
- Required Documentation: A valid, clear, government-issued photo ID (passport, national ID card, or driving license) valid for at least six months.
- Proof of Address: A valid utility bill or bank statement, no older than three months, is required.
- Due Diligence Standards: All documents must be provided in color, with all details clearly visible. Failure to provide this information without a valid explanation will be flagged as suspicious, and WEN LTD may decline the business relationship.
4. Internal Controls and Monitoring
WEN LTD maintains internal procedures to monitor client activity and identify unusual behaviors.
- Risk-Based Approach: A dedicated unit reviews client profiles and conducts due diligence based on risk ratings.
- Suspicious Activity: Staff are trained to recognize unusual patterns, such as complex or large transactions, and escalate concerns to the Compliance Officer.
- Reporting: Any identified suspicious activity will be reported to the Financial Intelligence Authority (FIA) of Saint Lucia. Per law, "tipping off" a client regarding an investigation is strictly prohibited.
- Record Keeping: In accordance with Saint Lucian law, all client records and transaction data will be kept for at least seven (7) years.
5. Enhanced Customer Due Diligence (CDD) Measures
WEN LTD carries out enhanced CDD in high-risk situations, including:
- When a customer is identified as a Politically Exposed Person (PEP).
- When a customer originates from a country identified by the FATF as having significant AML/CFT shortcomings.
- In cases of unusual or high-volume activity.
Source of Funds (SOF): Clients may be required to verify their source of wealth with supporting evidence, such as pay slips, tax returns, audited accounts, or sale documents. If a client cannot provide sufficient evidence, WEN LTD reserves the right to suspend the account or terminate the relationship.
6. Employee Training and Compliance Team
WEN LTD provides regular AML/CFT training for all employees, covering:
- Identification and reporting protocols for suspicious transactions.
- Current trends in money laundering and terrorist financing.
- Internal policies for reporting and risk mitigation.
Compliance Officer: A designated Compliance Officer is responsible for overseeing the daily operations of the AML/CFT program. The team regularly conducts compliance testing to ensure adherence to Saint Lucian statutory requirements.
7. Policy Review
This policy is reviewed annually to ensure it remains in line with the requirements of the Saint Lucia Financial Services Regulatory Authority (FSRA), the Financial Intelligence Authority (FIA), and evolving internal business practices.