Financially Limited

AML POLICY

Anti Money Laundering Policy

Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.Within the New Zealand alone it is estimated that L23 billion is laundered on an annual basis and on globally in revenue terms the amount of money laundered would make it the third largest industry.In response to the scale and effect of money laundering the New Zealand, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for New Zealand firms and outline the offences and penalties for failing to comply. Whilst Financially Limited are currently unregulated and do not fall with the scope of the AML/CTF obligations in the New Zealand the senior management have implemented systems and procedures that meet the New Zealand AML legislation. This decision reflects the senior managements desire to prevent money laundering and not be used by criminals to launder proceeds of crime.

NEW ZEALAND AML LEGAL AND REGULATORY FRAMEWORK

The NEW ZEALAND AML regime is set out in the following legislation and regulations:

The Proceeds of Crime Act 2009 (AML/CFT Act), places obligations on New Zealand’s financial institutions, casinos, virtual assets service providers, accountants, lawyers, conveyancers and high value dealers to detect and deter money laundering and terrorism financing.

The Act ensures that businesses take appropriate measures to guard against money laundering and terrorism financing. This enhances the reputation of individual businesses, and of New Zealand as a safe place in which to do business.

The Act came into full force on 30 June 2013.

ANTI-MONEY LAUNDERING (AML) POLICY

The Financially Limited AML Policy is designed to prevent money laundering by meeting the New Zealand AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:

• The appointment of a Money Laundering Reporting Officer (MLRO) who has sufficient level of seniority and independence and who has responsibility for oversight of compliance with relevant legislation, regulations, rules and industry guidance;
• Establishing and maintaining a Risk Based Approach (RBA) towards assessing and managing the money laundering and terrorist financing risks to the company;
•  Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);
•  Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
•  Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

The maintenance of appropriate records for the minimum prescribed periods; Training and awareness for all relevant employees.