Purpose:

This policy outlines the procedures and measures undertaken by ClaimRegulator to prevent money laundering activities and ensure compliance with relevant Anti-Money Laundering legislation.

Legal Framework:

ClaimRegulator adheres to the provisions of the Money Laundering and Terrorism (Prevention) Act of 2011, focusing on defining and criminalizing the laundering of proceeds from serious criminal offenses.

Procedures:

The Company implements the following procedures as mandated by the Act:

Identification and Due Diligence Procedures of Clients:

• Implemented when establishing a business relationship.
• Applied for one-off transactions of USD15,000 or more.
• Triggered in case of suspected money laundering, terrorist financing, or doubts about client identification data.

Client Identification and Due Diligence:

• Completed before the establishment of a business relationship or transaction.
• Simplified due diligence for low and normal-risk clients.
• Enhanced due diligence for high-risk clients and politically exposed persons.

Client Risk Classification:

• Low-risk customers: Efficiently identifiable individuals/entities with consistent transactions.
• Normal-risk customers: Identifiable individuals/entities with transactions in line with their economic profile.
• High-risk clients: Pose a higher-than-average risk, subject to enhanced due diligence.

Record Keeping:

The Company retains records of:

• Clients’ names, addresses, and official identification documents.
• Counterparty details.
• Forms of instruction or authority.
• Account details for funds paid.
• Forms and destinations of payments made by the business to clients.
• Business correspondence.

Client Refusal or Failure:

Failure or refusal by a client to submit required data without adequate justification may raise suspicion. In such cases, the Company may consider reporting to the Financial Intelligence Unit and refrain from establishing a business relationship.

ClaimRegulator is committed to maintaining the highest standards of compliance with anti-money laundering regulations and safeguarding against illicit financial activities.

Updates

The Company has the right to amend the current Policy as per its discretion and at any time it considers is suitable and appropriate. In such an event the Company will notify the client accordingly. The Company shall review and amend the current policy at least on an annual basis. The Policy is available for review by clients upon request and it is uploaded to the Company’s website.

I have read, understood and agreed to the risk disclosure statement and the trading policies and procedures set out above.