nealthy (hereafter referred to as “nealthy” or “the Company”) has implemented this Anti-Money Laundering Policy (“AML Policy”) to prevent money laundering and terrorist financing in relation to its business. nealthy requires all directors, officers, employees, contractors, and agents (collectively, “Representatives”) to read, understand, and follow this AML Policy in the course of performing services for the Company. nealthy also expects vendors and other business partners (collectively, “Business Partners”) to adopt and follow appropriate risk-based compliance standards to prevent money laundering and the financing of terrorism in relation to the services that they perform for the Company. This below is a summary of nealthy’s AML program and policy.
nealthy holds a prohibitive stance towards anyone who breaches laws and regulations relating to Money Laundering, Terrorist Financing, Sanctions, Bribery and Corruption, Tax Evasion and Fraud.
At nealthy, we understand that tackling financial crime is the right thing to do, not just because legislation tells us so. Our approach to preventing financial crime seeks to tackle the harm generated, as well as supporting compliance with relevant financial crime legislation and regulation, along with adopting the relevant guidance and recommendations set out by the Financial Action Task Force. nealthy’s approach to compliance with financial crime legislation and regulation considers not only the letter, but also the spirit of applicable laws and regulation.
Financial Crime Program
The cornerstone of our financial crime program is a suite of policies designed to comply with the legal and regulatory requirements relating to Anti-Money Laundering and Counter Terrorist Financing. These policies set the minimum mandatory control requirements, which must be adhered to by all employees within the Company.
nealthy’s approach to financial crime is built on the following pillars:
- Policies, procedures and system controls (including transaction monitoring) – to ensure that the Company seeks to prevent, identify and address financial crime through our operations, products, services and customers;
- Independent Audit – to continuously assess the effectiveness of our controls;
- Regular risk assessments – to ensure we align and continue to strengthen procedures in line with our inherent risks; this is an ongoing process and the Company will continue to strengthen and adopt prevention procedures as appropriate;
- Due diligence/Know Your Customer (“KYC”) – to enable us to understand our customers. The following measures are in place in order for nealthy to do this (list not exhaustive): 1) Customer identification and verification and the identification of beneficial owners; 2) Enhanced due diligence conducted on our customers displaying higher risk characteristics; 3) Screening our customers against relevant politically exposed persons (PEP) and terrorist lists;
- Colleague and customer training/awareness – to ensure that everyone understands the role they play in tackling financial crime; and
- MLRO – the MLRO will be the cornerstone of our Financial Crime Program as it is their responsibility to ensure implementation within the Company.
Due Diligence Process
In order to fully understand the risks posed to the Company by customers, we have implemented a KYC process. nealthy’s identification and verification process requires the customer to provide reliable, independent source documents, data or information.
nealthy will take the necessary steps to confirm the authenticity of documents and information provided by customers. All legal methods for double-checking identification information will be used and nealthy reserves the right to investigate certain customers who have been deemed to be high-risk or suspicious, which may include applying Enhanced Due Diligence measures which will further allow the Company to understand the customer.
Customer identification information will be collected, stored, shared and protected strictly in accordance with internal data protection and privacy policies and related regulations.
Money Laundering Reporting Officer (“MLRO”)
An MLRO plays an important role in an organisation's battle against money laundering. Most jurisdictions with an AML regulatory framework require organisations to appoint an MLRO who is in charge of the firm’s AML policy and financial crime program.
An MLRO holds a key role in protecting the integrity of the financial system. The officer carrying out this function must make informed decisions as to whether a business is being used as a vehicle to launder the proceeds of criminal activity or provide financial support to terrorists; as such, the MLRO has reporting obligations to local authorities.
Within nealthy, the MLRO is responsible for developing and enforcing the policies and procedures of our Financial Crime Program. The MLRO is required to report any violations of the AML Program directly to the Board and CEO. In addition, the MLRO is responsible for recording and filing Suspicious Activity Reports (“SAR”)/Suspicious Transaction Reports (“STR”), Currency Transaction Reports (“CTR”) and performing an AML Program audit at least annually, which includes the Business Wide Risk Assessment.
Transaction Monitoring and SAR/STR Reporting
Transaction Monitoring is key to any organisation's armoury when it comes to combating money laundering/terrorist financing. nealthy employs automated transaction monitoring solutions that assist the Company in building a holistic overview of a customers transaction behaviour; this coupled with the information that we obtain at onboarding helps us understand the customer and whether the overall activity is in-line with expectations. The MLRO reserves the right to decide whether further information is required from the customer.
The MLRO will file a SAR/STR if they know, suspect or have reason to suspect illicit activities have occurred while using the Company’s products and services. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. The MLRO reviews and investigates unusual activity to determine if sufficient information has been collected to justify the filing of a SAR/STR.
In line with the international standards, nealthy has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the risks identified. This will allow resources to be allocated in the most efficient way.
An employee AML training program is established within nealthy. The responsibility falls on the MLRO to create, review and maintain the training material and deliver it to existing employees as well as new employees.
The purpose of the training program shall be to familiarise all employees of the Company with the Company’s specific AML/CTF policies and procedures and provide instruction for recognition of suspicious activities. In addition, the MLRO will ensure that employees are trained on the obligation to report unusual transactions to the MLRO. All employees are required to complete a post training assessment, the results of which are captured and maintained by the MLRO.