AUSTRAC-COMPLIANCE AML/CTF PROGRAM

ABOUT THIS PROGRAM 

This document outlines ProClipse Consulting FZ LLC's Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Process for our Australian operations, in compliance with the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act) and the Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) (AML/CTF Rules). 

This program is covering the processes and action that we designed to identify, mitigate, and manage the risk of our products or services being used for money laundering or terrorism financing.

GLOBAL APPLICATION AND ENHANCED COMPLIANCE

While this program is specifically designed for AUSTRAC compliance in our Australian operations, ProClipse Consulting FZ LLC recognizes the value of applying robust AML/CTF measures consistently across our international footprint. 

1. Extended Application of AUSTRAC-Compliant Procedures

   1. Risk-Based Approach

      • Elements of this AUSTRAC-compliant program may be applied to our non-Australian operations based on comprehensive risk assessments.

      • The Global AML Compliance Committee will decide on extending specific procedures, considering:

        • Local regulatory requirements

        • Operational similarities to Australian business

        • Risk profile of the specific jurisdiction

   2. Enhanced Due Diligence

      • In jurisdictions with less stringent AML/CTF regulations, we may implement more robust measures based on this AUSTRAC-compliant program.

      • This approach ensures consistency in our risk management and demonstrates our commitment to best practices globally.

   3. Technology and Systems

      • Where beneficial, we will extend the use of advanced AML/CTF technologies and systems developed for AUSTRAC compliance to other jurisdictions.

2. Exceeding Minimum Legal Requirements

   ProClipse Consulting is dedicated to going beyond minimum legal requirements in AML/CTF compliance where appropriate:

   1. Stricter Thresholds

      • We may implement lower thresholds for reporting and enhanced due diligence than legally required in certain jurisdictions, based on our risk assessment.

   2. More Frequent Reviews

      • Customer due diligence, risk assessments, and policy reviews may be conducted more frequently than mandated by local laws.

   3. Comprehensive Training

      • Our global AML/CTF training program may exceed local requirements, ensuring all staff worldwide are held to the highest standards of compliance awareness.

   4. Advanced Monitoring

      • We may deploy more sophisticated monitoring and screening tools than locally required, especially in high-risk jurisdictions or for high-risk products/services.

3. Implementation and Oversight

   1. Global AML Compliance Committee

      • Responsible for decisions on extending AUSTRAC-compliant procedures to other jurisdictions

      • Conducts annual reviews of global AML/CTF standards and practices

   2. Local Compliance Officers

      • Work with the Global AML Compliance Committee to implement enhanced measures

      • Provide regular feedback on the effectiveness and appropriateness of extended procedures

   3. Documentation and Justification

      • All decisions to apply AUSTRAC-compliant procedures beyond Australia or to exceed minimum legal requirements will be thoroughly documented and justified.

   4. Regular Review

      • The application of enhanced measures will be reviewed annually to ensure continued relevance and effectiveness.

PROGRAM COMPONENTS, PROCESS & ACTION PLANS

1. ML/TF Risk Assessment 

   • Action: Conduct a comprehensive ML/TF risk assessment

   • Frequency: Annually, with quarterly reviews

   • Responsibility: Risk Assessment Team led by AML Compliance Officer

   • Deliverable: Detailed risk assessment report with mitigation strategies

2. AML/CTF Risk Awareness Training Program 

   • Action: Develop and implement role-specific training modules

   • Frequency: Quarterly training sessions, annual comprehensive update

   • Responsibility: Training Manager in collaboration with AML Compliance Officer

   • Deliverable: Training completion reports, assessment results

3. Employee Due Diligence Program

   • Action: Implement pre-employment screening and ongoing risk assessments

   • Frequency: Pre-employment and annual reviews for existing employees

   • Responsibility: HR Manager in coordination with AML Compliance Officer

   • Deliverable: Employee risk profiles, screening reports

   • Whistleblowing mechanism: Implement a secure, anonymous reporting system for employees to report AML/CTF concerns without fear of retaliation.

4. Program Adoption and Oversight 

   • Action: Present AML/CTF program for board approval

   • Frequency: Annual review by board, quarterly updates to senior management

   • Responsibility: AML Compliance Officer

   • Deliverable: Board meeting minutes, quarterly compliance reports

5. AML/CTF Compliance Officer

   • Action: Appoint and empower AML Compliance Officer for Australian operations

   • Frequency: Ongoing role with annual performance review

   • Responsibility: CEO and Board of Directors

   • Deliverable: Job description, performance metrics, regular compliance reports

6.  Independent Review Process

   • Action: Engage external auditor for AML/CTF program review

   • Frequency: Annually

   • Responsibility: AML Compliance Officer to coordinate, Board to approve

   • Deliverable: Audit report with actionable recommendations

7. AUSTRAC Feedback Response Procedures

   • Action: Establish a feedback review committee (Protocol)

   • Frequency: Meet within 5 business days of receiving AUSTRAC feedback

   • Responsibility: AML Compliance Officer to lead committee

   • Deliverable: Action plan addressing AUSTRAC feedback

8. Reporting Procedures

   • Action: Implement automated system for TTRs, SMRs, and IFTIs

   • Frequency: Real-time monitoring, daily review of alerts

   • Responsibility: AML Analyst Team, overseen by AML Compliance Officer

   • Deliverable: Timely submission of reports to AUSTRAC, internal summary reports

9. AUSTRAC Enrolment and Registration Maintenance

   • Action: Review and update AUSTRAC enrolment details

   • Frequency: Quarterly review, immediate update for any changes

   • Responsibility: AML Compliance Officer

   • Deliverable: Up-to-date AUSTRAC enrolment records

10. Know Your Customer (KYC) Procedures

    • Action: Implement digital KYC system with risk-based approach

    • Frequency: At onboarding and regular intervals based on risk profile

    • Responsibility: Customer Onboarding Team, overseen by AML Compliance Officer

    • Deliverable: Comprehensive customer profiles, due diligence reports

11. Transaction Monitoring Program

    • Action: Deploy AI-powered transaction monitoring system

    • Frequency: Real-time monitoring, daily review of alerts

    • Responsibility: AML Analyst Team

    • Deliverable: Daily alert reports, investigation outcomes

12. Record Keeping

    • Action: Implement secure, cloud-based document management system

    • Frequency: Ongoing, with quarterly system audits

    • Responsibility: IT Manager in collaboration with AML Compliance Officer

    • Deliverable: Audit trails, accessibility reports

13. Sanctions Screening

    • Action: Integrate real-time sanctions screening into all business processes

    • Frequency: Real-time screening, daily list updates

    • Responsibility: AML Analyst Team

    • Deliverable: Screening reports, match investigation outcomes

14. Politically Exposed Persons (PEPs) Management

    • Action: Implement PEP identification and enhanced due diligence procedures

    • Frequency: At onboarding and ongoing monitoring

    • Responsibility: Customer Onboarding Team and AML Analyst Team

    • Deliverable: PEP register, enhanced due diligence reports

15. Ongoing Risk Management

    • Action: Establish risk management committee for AML/CTF

    • Frequency: Monthly meetings, ad-hoc for significant changes

    • Responsibility: Risk Management Committee led by AML Compliance Officer

    • Deliverable: Monthly risk reports, updated risk mitigation strategies

16. Compliance Reporting

    • Procedures for Action: Develop automated compliance reporting system

    • Frequency: As required by AUSTRAC, monthly internal reports

    • Responsibility: AML Compliance Officer

    • Deliverable: Timely AUSTRAC reports, monthly board briefings

REVIEW & UPDATE

This program is subject to regular review and update to reflect changes in our business, regulatory environment, and global risk landscape. The Global AML Compliance Committee, in collaboration with local compliance officers, is responsible for ensuring the program's effectiveness and relevance across all our operations.

This AUSTRAC-Compliant AML/CTF Program, enhanced with global application measures, demonstrates ProClipse Consulting FZ LLC's commitment to maintaining the highest standards of AML/CTF compliance globally. By extending best practices beyond Australian operations and often exceeding minimum legal requirements, we ensure a robust, consistent approach to AML/CTF risk management across all jurisdictions in which we operate.

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