FIRM’S POLICIES AND PROCEDURES
Policy statement
Goldcross Cargo is committed to maintaining effective procedures to prevent money laundering, terrorist financing and related criminal activity. The firm will apply appropriate systems, controls and governance to manage AML risk proportionately and in line with applicable legislation, regulatory expectations and customer obligations.
These procedures are designed to ensure that the firm understands who its customers are, monitors transactions for unusual patterns, and escalates any concerns through the nominated reporting line. Where risk indicators arise, the firm will not proceed with a transaction until the relevant review has been completed in accordance with its policies.
All staff and representatives must take responsibility for identifying and escalating concerns to [name of MLRO]. The firm’s policies apply to all business activities, including but not limited to freight booking, payment arrangements, customer onboarding, account management and related administration.
Risk assessment and management
The firm will assess, document and review the money laundering and terrorist financing risks associated with its business activities, customer base, products, services, geographies and counterparties. This assessment will consider the nature of the services provided, the jurisdictions involved and the likelihood of exposure to suspicious activity.
Where new risks are identified, the firm will review and update its procedures accordingly. Risk management will include the design and implementation of controls relevant to the size, complexity and nature of the business, and will be monitored at board or management level as appropriate.
Firm level risk assessment
The firm’s risk assessment recognises that the risks associated with cargo, freight and logistics services may vary according to customer profile, destination, payment method, transaction value and the nature of the goods being shipped. The assessment must be reviewed periodically and amended where changes in operations, regulation or market conditions require it.
Where higher-risk factors are identified, enhanced due diligence and additional review steps will be applied before the firm accepts or proceeds with the arrangement.
Customer due diligence measures
The firm will undertake customer due diligence measures before or during the establishment of the business relationship where appropriate, and on a risk-sensitive basis in relation to ongoing arrangements. This includes obtaining sufficient information to identify the customer and understand the purpose and intended nature of the transaction.
Where the customer is an individual, the firm will establish identity and, where relevant, address information and other information needed to assess the transaction. Where the customer is an entity, the firm will understand the business purpose, ownership structure and relevant beneficial ownership information.
Enhanced due diligence will be applied in situations involving higher risk, unusual transactions, politically exposed persons, sanctions exposure or other indicators which require additional review.
Ongoing monitoring
Ongoing monitoring is a core part of the firm’s AML controls. Transactions and customer relationships will be reviewed on a continuing basis to identify unusual patterns, unexplained complexity, sudden changes in behaviour or other indicators that may require follow-up.
The monitoring process includes a review of booking information, payment activity, route information, documentation, and any changes to the customer profile or transaction narrative. Any unusual or inconsistent information must be investigated before the shipment proceeds.
Reporting of suspicious transactions
If a suspicious transaction or activity is identified, the matter must be reported without delay to the nominated Money Laundering Reporting Officer or other designated authority within the firm. The report should include the facts, risk indicators and any supporting information that may be relevant to the review.
The firm will not proceed in a way that could prejudice a suspicious activity report. Staff must not attempt to investigate or assess the underlying criminality themselves beyond the information required to complete the escalation process and maintain confidentiality.
Avoiding tipping off
The firm will ensure that information relating to suspicious activity is not disclosed to the customer or any third party in a manner that could reasonably be expected to prejudice an investigation. Any internal handling of such matters must be conducted in a confidential and controlled manner in accordance with this policy.
Record keeping
Goldcross Cargo will maintain records of customer due diligence, risk assessments, transaction records, supporting documentation and suspicious activity reports in line with legal and regulatory requirements. Records will be kept in a manner that allows timely retrieval and sufficient retention for the required period.
Records should be accurate, complete and capable of demonstrating how decisions were reached and what steps were taken to assess risk or report concerns.
Training
The firm will provide appropriate AML and financial crime training to staff and relevant personnel. Training will cover the legal and regulatory framework, indicators of suspicious activity, customer due diligence obligations, escalation procedures and the need to maintain confidentiality.
Training will be refreshed as needed to reflect changes in law, regulation, risk profile and business operations. Attendance and understanding of this training will be monitored as part of the firm’s governance arrangements.
Internal control, monitoring and management of compliance
The firm will maintain an appropriate system of internal controls to support compliance with AML obligations. This includes documented procedures, management review, escalation pathways, periodic testing and independent oversight where appropriate.
Senior management is responsible for ensuring the policy is implemented, communicated and reviewed regularly. Compliance with these procedures is expected from all staff, contractors and representatives acting for the firm.
Internal communication of such policies and procedures
The firm will communicate these policies and procedures to all relevant employees and business partners. Any updates will be distributed through internal channels and accompanied by guidance on how to apply the policy in day-to-day operations.
Where a concern arises, staff are expected to seek guidance promptly and escalate it in line with the firm’s reporting procedures. This ensures the firm remains alert to criminal activity and can demonstrate a clear and consistent approach to compliance.
Failure to comply with AML controls may result in disciplinary action and may also expose the firm to regulatory concern. The firm expects all employees to act honestly, exercise professional judgment and support the implementation of these controls at all times.