ANTI‐MONEY LAUNDERING/ANTI‐TERRORIST FINANCING (“AML/ATF”) POLICY STATEMENT
LOM is strongly committed to preventing the use of its operations for money laundering or any activity which facilitates money laundering or the funding of terrorist or criminal activities. Accordingly, the Company will comply with all applicable laws and regulations designed to combat money laundering activity and terrorist financing as well as guidance notes, enacted by the Bermuda Monetary Authority.
Through the following Policy Guidelines, LOM is committed to;
- Have an AML policy that covers all businesses and customers of LOM
- Designate a person responsible for compliance with LOM’s AML policy
- Have procedures that require the collection of information in order to verify and identify each new customer, individuals and businesses
- Only accept clients whose identity is established by conducting due diligence appropriate to the risk profile of the client
- Record and maintain transactional customer data for the required period of time
- Provide regular anti-money laundering awareness training to all staff and to include procedures for identifying unusual and potentially suspicious activity and reporting suspicious activity to competent authorities
- Cooperate with competent legal and regulatory authorities if so requested
This policy statement is meant to set the minimum standards to which LOM will adhere to. The LOM Group has developed extensive Anti‐Money Laundering/Anti‐Terrorist Financing policies and procedures and in some circumstances set a higher standard than that established by the applicable law. It provides the basis to further develop specific policies and operational procedures within each business line, support function and geographic location to meet Group‐wide standards.
LOM requires valid photo identification, references (if account not opened in person), and residential addresses of all beneficial account owners and signatories. If the account is held in the name of a corporation, we require disclosure of all beneficial individual owners of the corporation, as well as valid photo identification, references, and residential addresses for the beneficial owners and signatories. Corporate accounts must provide copies of their certificate of incorporation to evidence their legal incorporation, as well as other corporate documents.
The Head of Compliance monitors operations, and implements and enforces policies necessary to protect the firm and its clients. The Head of Compliance reports to senior management and the board of directors, and is responsible for the management of the firms overall compliance and AML risk.
Client Monitoring & Screening
LOM utilizes the services of two external third party vendors in satisfying its due diligence requirements. These vendors are used to carry out extensive due diligence on new and existing clients, signatories and beneficial owners as part of normal account opening procedures. LOM’s subscription with these vendors includes access to various international sanction lists and databases from various sources, including the U.S State Department OFAC list, the Bank of England Sanctions list, SEC litigation releases, and many more.
Annually, all staff are required to read and acknowledge the Company’s AML/ATF policies and procedures and receive face to face and/or web-based training on AML/ATF and Financial Crime. These policies require that staff be alert to and report any illegal, suspicious or unusual activity. Management officers must be aware of all legal requirements pertinent to their activities; must make sure that these requirements are communicated to their staff and are reviewed regularly; and must manage and supervise their staff to ensure that the law, the Guidelines and other policies and procedures are followed.
KNOW YOUR CUSTOMER (“KYC”) POLICY STATEMENT
As a financial institution, we are at risk for our facilities being used for purposes of dealing with proceeds of crime or terrorist financing, as are all financial institutions in all jurisdictions worldwide. LOM is committed to reducing such risk to the best of its ability.
LOM aspires to be the premier offshore financial company, through a commitment to providing a consistently superior standard of service and investment products to our customers. LOM has an equal commitment to preventing money laundering and terrorist financing, and complying will all applicable legislative requirements. Senior management is responsible for and accountable for ensuring compliance with such regulations. The Company expects its managers and staff to promulgate a culture of applying the “know-your-customer” tenet in the execution of daily responsibilities, as well as to constantly “think risk”.
LOM’s objectives of our KYC policy include:
- Ensuring that only legitimate and bona fide customers are accepted
- Ensuring that customers are properly identified and understanding the risks they may pose
- Verifying the identity of customers using reliable and independent documentation
- Monitoring customer accounts and transactions to prevent or detect illegal activities
- Implementing processes to effectively manage the risks posed by customers trying to misuse facilities.
This KYC policy applies to all new and existing customer relationships and to all products and services offered by the LOM Group of Companies. Such policies and procedures are set group-wide and followed uniformly by each sales office. Policies are developed in accordance with regulations and regulator guidelines in each of the two jurisdictions LOM operates in, as well as standard industry good practice. Each jurisdiction has extensive regulations specifically designed to combat money laundering and terrorist financing, which include detailed policy and procedural requirements regarding accepting new clients, documentation, file retention and reporting suspicious activities to local authorities. All staff receive on-going anti-money laundering training.
For more information regarding LOM’s AML and/or KYC policy please contact the following:
Nigel Bell, Compliance Manager & MLRO Office - 441 294-7010 or firstname.lastname@example.org