Overview

Brocard is committed to full compliance with the Proceeds of Crime (Money Laundering) and Terrorist Financing Act, as well as all other applicable laws and regulations that impact its operations.
The company is dedicated to implementing and enforcing the procedures outlined in this document (referred to as the AML Policy). Brocard also maintains internal guidelines to ensure thorough adherence to AML compliance standards.
Brocard reserves the right to develop, modify, and enforce this AML Policy as necessary to ensure compliance with all applicable provisions. The company also establishes internal procedures to maintain compliance with anti-money laundering and counter-terrorist financing regulations.

Compliance Officer

Brocard has appointed a Compliance Officer to oversee and manage the implementation of the AML Policy.

The Compliance Officer is responsible for collecting, analyzing, and investigating information related to suspicious activities, as well as ensuring that employees receive appropriate training on AML practices.

The Compliance Officer is also responsible for maintaining all documentation used for client or corporate identification.

Customer Identification Procedures

Brocard has established procedures for customer identification and verification that vary based on the transaction amounts involved.

For customer identification, the following documentation is required:

Personal Account Verification:

• Valid identification (passport, driver’s license, national ID card);
• Proof of address (bank statement, utility bill).

Business Account Verification:

• All documentation required for personal account verification;
• Corporate documents, including the certificate of incorporation, company charter, Articles of Incorporation (if applicable), and documentation proving the authority of the individual acting on behalf of the company.

Transaction Monitoring

Brocard employs a range of monitoring tools and algorithms to ensure the timely execution of all required KYC procedures, detect individuals on sanctions lists or those identified as politically exposed persons (PEPs), and conduct comprehensive automated online monitoring.

Financial data analysis includes:

• Screening against sanctions lists;
• Monitoring user activity and system interactions;
• Tracking transactions;
• Evaluating account balances, exchange rate fluctuations, and other relevant metrics;
• Utilizing tools that enhance the accuracy of manual data analysis;
• Employing a risk-based approach to determine account and transaction risk levels.

Detection of Suspicious Activity

Brocard recognizes the importance of identifying and investigating suspicious activities through close monitoring of customer transactions. Any transaction that appears to be linked to money laundering activities will be flagged as suspicious.

Suspicious activity may be identified through employee observations, gathered intelligence, or anomalies in transaction patterns. Such activities may include transactions involving illicit funds, attempts to bypass currency transaction reporting requirements, significant deviations from typical customer behavior, unauthorized third-party access to accounts, or transactions with no legitimate business purpose.

Brocard applies heightened scrutiny and manual monitoring techniques to detect money laundering and suspicious activities. The company may also request additional documentation to verify the legitimacy and economic purpose of any flagged transactions.

The Compliance Officer will regularly review and update Brocard’s systems to ensure the effective detection of suspicious activities.

In accordance with applicable laws and international standards, Brocard may, when necessary and without prior customer consent, report any suspicious transactions to the relevant regulatory or law enforcement authorities.

Reporting requirements may vary based on the nature and size of the transaction.

Brocard regularly consults lists published by international authorities to ensure that neither its customers nor their jurisdictions are linked to known terrorists, terrorist organizations, high-risk countries, or entities subject to sanctions.

Brocard conducts continuous due diligence on its customers and scrutinizes their transactions to ensure alignment with the company’s knowledge of their business activities and, when necessary, the sources of their funds.

Third-Party Involvement

Brocard engages third-party service providers for certain business operations. During initial and ongoing due diligence, the company seeks to determine whether any third-party provider is subject to investigations or legal actions and ensures that they hold all necessary licenses and approvals before entering into a business relationship.

For internal operations, Brocard carefully vets all potential employees to identify any roles that may be vulnerable to money laundering risks. Additionally, the company has implemented training programs to educate staff on customer identification procedures and anti-money laundering measures.

Civil and Criminal Penalties

Government authorities of different countries and, in some cases, international organizations, may impose severe civil and criminal penalties against any person who violates the laws and regulations referred to in the AML Policy.

Under certain circumstances, companies may be deemed criminally responsible for the actions of their employees. In this regard, it is important for the employees of our Corporate Customers to have adequate knowledge in this sphere; it is also important that such Corporate Customers should ensure the compliance of their employees’ actions with the said laws and regulations.

Compliance Statement

The Corporate Customer (the Corporate Customer’s authorized employee) certifies that they have read and understood this AML Policy, and that they (or their company) shall operate in full compliance with the requirements and standards outlined in the AML Policy and comply with all applicable laws and other regulations and requirements governing its activities as a Corporate Customer.

The Corporate Customer (the Corporate Customer’s authorized employee) acknowledges that they are responsible for their actions in accordance with the effective AML laws and shall bear responsibility pertaining to failure to comply with such laws.