1. Introduction

Right Time Trading (“the Company”, “Right Time”, “We”, “Us”, “Our”) is dedicated to
implementing and establishing comprehensive anti-money laundering (AML) and
counter-terrorist financing (CTF) procedures based on the latest legislation and
regulations issued in the country where the Company operates.
Money laundering is the process of cycling large amounts of illegally obtained money
(cash-based, electronic, or in other forms such as cryptocurrency) into legitimate
enterprises, assets, and accounts to make it appear that the income was obtained legally
and, therefore, provide more flexibility with the income (“clean money”).
Money laundering can take many forms, and while sophisticated controls are in place in
the banking and related sectors, criminals and their financial specialists are also
developing increasingly complex methods for concealing illegal income and feeding it
into businesses to realise legitimate income.
All businesses present attractive opportunities for criminals and their specialist financial
cohorts to target due to the high-value assets and investment opportunities that can
provide a legitimate ongoing income.
There is also the threat of income from money laundering being used to finance terrorist
activities, with the root source of the funds coming from related actions.
This policy covers the controls that Right Time Trading has in place to mitigate any
perceived money laundering attempts and the methods that we use to train our staff and
notify the authorities of suspicious activity so a further investigation can be undertaken.

Relevant Laws

1. The Proceeds of Crime Act 2002 (amended in 2015)
– This Act provides the legal framework for confiscating and recovering the proceeds of
crime, as well as the obligations of financial institutions to report suspicious activities.
2. The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the
Payer) Regulations 2017
– These regulations implement the EU’s Fourth Money Laundering Directive (4MLD) and
Fifth Money Laundering Directive (5MLD) into UK law, setting out detailed requirements
for customer due diligence, reporting, and record-keeping.
3. The Terrorism Act 2000 (amended in 2006 and 2008)
– This Act establishes offences related to terrorist funding and sets out the
responsibilities of financial institutions to report knowledge or suspicion of terrorist
financing.
4. The Financial Action Task Force (FATF) Recommendations
– As an international standard, the FATF Recommendations guide jurisdictions in
implementing robust AML and CTF measures. Right Time Trading adheres to these
recommendations as part of its commitment to global best practices.
5. The Anti-Money Laundering and Counter-Terrorism Financing Act 2020 (UK)
– This recent Act enhances the legal framework for combating money laundering and
terrorist financing, introducing stricter penalties and enhanced regulatory oversight.
Commitment to Compliance: By the legal framework prescribed by the Acts above, Right
Time Trading is committed to maintaining a robust compliance program that includes the
following key components:
1. Internal Controls and Procedures
– System of Internal Controls: Establishing and maintaining a system of internal
controls and procedures designed to ensure ongoing compliance with AML and CTF laws
and regulations. This includes customer due diligence (CDD), enhanced due diligence
(EDD), and ongoing monitoring of transactions.
– Policies and Procedures: Developing comprehensive AML and CTF policies and
procedures that are regularly reviewed and updated to reflect legislation and best
practice changes.
2. Independent Testing
– Internal and External Audits: Conduct regular independent testing for compliance
through internal and/or external audits. These audits assess the effectiveness of the AML
and CTF program and identify areas for improvement.
– Continuous Improvement: Implementing audit recommendations to enhance the
effectiveness of AML and CTF controls and ensure compliance with regulatory
requirements.
3. Training and Awareness
– Personnel Training: Providing ongoing training for all personnel on AML and CTF
regulations, the identification of suspicious transactions, and the procedures for
reporting such activities. This training ensures that employees are knowledgeable about
their responsibilities and equipped to recognise and respond to potential money
laundering and terrorist financing activities.
– Role-Specific Training: Tailoring training programs to the specific roles and
responsibilities of employees to ensure that they understand the risks and controls
relevant to their functions.
4. Designation of a Compliance Officer
– Compliance Officer Appointment: Designating an appropriate officer responsible for
the continuous oversight and enforcement of compliance with the Acts. The Compliance
Officer is tasked with ensuring that the Company’s AML and CTF policies and procedures
are effectively implemented and adhered to.
– Reporting and Accountability: The Compliance Officer reports directly to senior
management and the board of directors, providing regular updates on the AML and CTF
program status and any significant issues or developments.
These AML and CTF procedures will take effect upon approval by the Company’s director
and shall remain in operation unless amended by the director’s authority. Any procedure
amendments will be communicated to all relevant personnel and integrated into the
Company’s compliance program.
2. Company Information
Right Time Trading is committed to upholding the highest standards of integrity and
transparency in all its operations. As a regulated financial services provider, Right Time
Trading adheres to strict legal and regulatory requirements to ensure the security and
compliance of its services.
– Trading Name: Right Time Trading operates under the trading name of Right Time
Trading LTD.
– Incorporation: Right Time Trading LTD is incorporated under registered No. 2023-00517
IBC by the Registry of International Business: Companies, Partnerships & Trusts.
– Registered Office: The registered office of Right Time Trading LTD is located at Pinnacle
St. Lucia, Robin Kelton Building, Choc Bay, PO Box CP 5600, Castries, St. Lucia.
3. Business Operations
Right Time Trading provides brokerage services in foreign exchange (Forex) and other
financial instruments to a global clientele. The Company’s services are designed to cater
to both individual and institutional investors, offering a range of trading options.
4. Roles and Responsibilities
All staff are responsible for being alert to Money Laundering and bringing any concerns
to the Nominated Officer.
The Nominated Officer will:
– Review (and, in some cases, instruct) AML Assessments.
– Be the point of contact for reporting.
– Report breaches or make queries through formal channels.
The directors and Senior Managers must:
– Identify, assess, and manage risks effectively in the business and how they may be
exploited to launder money or finance terrorism.
– Use risk assessment tools and relevant resources to identify high-risk countries
identified by the Financial Action Task Force, Foreign Commonwealth and Development
Office, financial sanctions targets, and Money Laundering Advisory Notice.
– Appoint a nominated officer to report suspicious activity to the National Crime Agency.
– Devote adequate resources to address the risk of money laundering and terrorism
through allocating budgets for formal training, ensuring adequate time and resources
are prioritised concerning high-value transactions, and conducting suitable risk
assessments of our clients.
5. Third-Party Tools Used for AML
Right Time Trading employs various third-party tools to enhance its Anti-Money
Laundering (AML) efforts. These tools provide essential customer due diligence,
transaction monitoring, risk assessment, and reporting capabilities leveraging advanced
technologies and specialised services; Right Time Trading ensures robust compliance
with AML regulations and effective detection and prevention of financial crime.
1. Customer Due Diligence (CDD) and Know Your Customer (KYC) Tools:
– Refinitiv World-Check

– World-Check is a comprehensive risk intelligence database that provides detailed
information on individuals and entities identified as high-risk. This includes politically
exposed persons (PEPs), sanctioned entities, and those linked to financial crime.
– Right Time Trading uses World-Check to screen new and existing customers against
global watchlists and databases, ensuring compliance with regulatory requirements and
identifying potential risks during the customer onboarding process.
– Refinitiv’s solutions are integrated into Right Time Trading’s KYC processes to verify
customer identities, assess risk levels, and ensure compliance with international AML
standards. The tool helps streamline onboarding by automating identity verification and
background checks.
– Jumio
– Jumio’s AI-powered identity verification solutions authenticate government-issued ID
documents and perform biometric verification, ensuring the authenticity of customer
identities for Right Time Trading.
– Onfido
– Onfido’s platform combines document verification with biometric analysis,
preventing fraud and accurately verifying customer identities for Right Time Trading.
2. Transaction Monitoring Tools
– Actimize
– Actimize is a leading provider of AML solutions, offering advanced analytics and
machine-learning capabilities for real-time transaction monitoring.
– Right Time Trading uses Actimize to monitor transactions for suspicious activity
continuously. The tool analyses transaction patterns, detects anomalies, and generates
alerts for further investigation. Actimize helps ensure that all transactions are scrutinised
for potential money laundering and terrorist financing activities.
– ComplyAdvantage
– ComplyAdvantage offers real-time transaction monitoring and risk assessment tools
that Right Time Trading uses to detect and prevent financial crimes. By leveraging
advanced algorithms and a comprehensive risk database, ComplyAdvantage enables
continuous monitoring and immediate identification of suspicious activities. Automated
alerts and detailed risk profiles facilitate swift investigation and compliance reporting,
enhancing Right Time Trading’s ability to maintain robust AML and CTF standards.
3. Risk Assessment and Screening Tools
– Trulioo
– Trulioo is a global identity verification service that provides access to over 400 data
sources in more than 100 countries. Right Time Trading uses Trulioo to verify customers’
identities during the onboarding process. The tool provides real-time identity verification,
ensuring accurate and complete customer information. Trulioo helps prevent identity
fraud and supports compliance with KYC and AML regulations.
– Kount
– Kount provides AI-driven fraud prevention solutions that deliver real-time risk
assessments and insights for Right Time Trading. By analysing customer transactions,
Kount helps identify and mitigate potential risks and fraudulent activities. The platform’s
advanced algorithms and comprehensive data sets enable Right Time Trading to
proactively address threats, ensuring secure and reliable financial operations.
4. Enhanced Due Diligence (EDD) Tools
– Dow Jones Risk & Compliance
– Dow Jones Risk & Compliance offers tools for conducting enhanced due diligence
and managing compliance risks. Right Time Trading utilises Dow Jones Risk & Compliance
to perform in-depth background checks on high-risk customers and entities. The tool
provides detailed reports on potential risks, including adverse media coverage, sanctions,
and legal proceedings. This information is critical for making informed decisions and
ensuring thorough due diligence.
6. Risk Assessments
1. Current Risk Assessment and Mitigation
At Right Time Trading, we employ a comprehensive risk assessment framework to
identify and mitigate potential risks associated with money laundering and terrorist
financing. This framework is designed to ensure compliance with international standards
and regulatory requirements.
1.1. Risk Assessment Process
1. Risk Identification
– Identify potential risk factors for customers, transactions, geographical locations, and
products/services offered.
– Utilise internal and external sources to gather information on emerging risks and
typologies.
2. Risk Evaluation
– Evaluate the identified risks based on their likelihood and potential impact on the
organisation.
– Use a risk scoring system to categorise risks as low, medium, or high.
3. Risk Mitigation Strategies
– Develop and implement controls to mitigate identified risks.
– Regularly review and update risk mitigation measures to ensure their effectiveness.
1.2. Key Risk Mitigation Measures
1. Enhanced Customer Due Diligence (CDD)
– Perform enhanced due diligence on high-risk customers, including those from highrisk jurisdictions or involved in high-risk industries.
– Obtain additional information on the customer’s background, source of funds, and
the nature of their business activities.
2. Transaction Monitoring
– Implement automated systems to monitor transactions in real time.
– Set thresholds for transaction values and volumes that trigger alerts for further
investigation.
– Analyse transaction patterns to identify unusual or suspicious activities.
3. Know Your Customer (KYC) Procedures
– Ensure thorough verification of customer identity through reliable and independent
sources.
– Collect and verify information on the beneficial owners of legal entities.
– Maintain updated customer profiles and perform periodic reviews to ensure
information remains current.
4. Segregation of Duties
– Separate responsibilities within the organisation to prevent conflicts of interest and
ensure checks and balances.
– Designate specific roles for customer onboarding, transaction monitoring, and
compliance oversight.
5. Staff Training and Awareness
– Regularly train employees on AML regulations, risk assessment procedures, and red
flags for suspicious activities.
– Foster a culture of compliance within the organisation by promoting awareness of
AML policies and procedures.
6. Independent Audits and Reviews
– Conduct regular audits of the AML program to assess its effectiveness and compliance
with regulatory requirements.
– Review audit findings and implement recommendations to address any identified
weaknesses or gaps.
2. Examples of Risk Mitigation in Practice
2.1. Scenario 1: High-Risk Jurisdiction Client
– A new client from a high-risk jurisdiction attempts to open an account and deposit a
large sum of money. The compliance team performs enhanced due diligence, including
verifying the client’s identity, source of funds, and business activities. Transactions from
this client are monitored more closely for any unusual patterns.
2.2. Scenario 2: Unusual Transaction Patterns
– The automated transaction monitoring system detects a client making a series of highvalue transactions that deviate from their normal activity. The compliance team
investigates these transactions, seeking additional information from the client and, if
necessary, reporting suspicious activity to the relevant authorities.
Continuous Improvement
Right Time Trading is committed to continuously improving its risk assessment and
mitigation framework. This involves staying informed about new and emerging risks,
adopting best practices, and leveraging advanced technologies to enhance the
effectiveness of our AML measures.
3. Criteria for Identifying High-Risk Customers
Identifying high-risk customers is a crucial component of Right Time Trading’s AML
policy. Due to their increased potential for involvement in money laundering or terrorist
financing activities, high-risk customers require enhanced due diligence and closer
monitoring. Right Time Trading employs a robust set of criteria to identify these
customers.
3.1. Criteria for Identifying High-Risk Customers
1. Geographical Risk
– High-Risk Jurisdictions: Customers from countries identified as high-risk by the
Financial Action Task Force (FATF) or other international bodies. These include countries
with weak AML regulations, high levels of corruption, or known to be havens for illicit
activities.
– Sanctioned Countries: Customers from countries subject to international sanctions or
embargoes.
2. Customer Type
– Politically Exposed Persons (PEPs): Individuals who hold or have held prominent
public positions, such as government officials, senior executives of state-owned
enterprises, or high-ranking military officers, including their family members and close
associates.
– Non-resident Customers: Customers who are not residents of the country where Right
Time Trading operates, particularly those from offshore financial centres.
– Anonymous or Nominee Accounts: Accounts opened under fictitious names or those
that use nominees to obscure the account holder’s true identity.
3. Business and Industry Risk
– High-Risk Industries: Customers are involved in industries known for higher money
laundering risks, such as gambling, casinos, money service businesses, real estate,
precious metals and stones, and cryptocurrency trading.
– Cash-Intensive Businesses: These are businesses that primarily deal in cash
transactions, making it difficult to track the source and destination of funds.
4. Transaction Patterns
– Unusual Transaction Volumes: Customers conducting transactions that are unusually
large compared to their known financial profile or business activities.
– Complex Transaction Structures: Transactions involving multiple intermediaries,
jurisdictions, or accounts, which complicate the tracing of funds.
– Frequent Large Deposits or Withdrawals: Repeated high-value transactions that do not
align with the customer’s known activities.
5. Account Activity
– Inconsistent Account Usage: Account activities that deviate significantly from the
customer’s established pattern or expected behaviour.
– Rapid Movement of Funds: Funds moved quickly through the account, particularly if
they are transferred to high-risk jurisdictions or third parties with no apparent legitimate
purpose.
6. Customer Behaviour
– Reluctance to Provide Information: Customers who are unwilling or hesitant to
provide requested information or documentation during the KYC process.
– Use of Third Parties: Customers use intermediaries or third parties to conduct
transactions on their behalf without a clear, legitimate reason.
7. Source of Funds
– Unverified Source of Wealth: Customers whose source of wealth or funds cannot be
adequately verified or appears inconsistent with their profile.
– High-Risk Funding Sources: Funds originating from high-risk areas, industries, or
activities known for higher money laundering risks.
3.2. Enhanced Due Diligence for High-Risk Customers
For customers identified as high-risk based on the criteria above, Right Time Trading
applies enhanced due diligence measures, including:
– Detailed Customer Information: Collect more comprehensive information on the
customer’s identity, business activities, source of wealth, and financial background.
– Increased Monitoring: Conducting more frequent and detailed monitoring of the
customer’s transactions and account activities.
– Senior Management Approval: Requiring approval from senior management before
establishing or continuing business relationships with high-risk customers.
– Regular Review: Periodically review the customer’s profile and transactions to ensure
ongoing compliance with AML requirements.
3.3. Examples of High-Risk Customers
– Scenario 1: A
new customer from a high-risk jurisdiction deposits significant money and requests
frequent international transfers. Enhanced due diligence is performed, including
verifying the source of funds and the purpose of the transactions, and the account is
subject to continuous monitoring.
– Scenario 2: An existing customer suddenly starts engaging in large, complex
transactions that deviate from their normal activity. The compliance team investigates
the changes in behaviour, seeks additional information, and monitors the account closely
for any suspicious activities.
4. Additional Verification Triggers
To further strengthen our Anti-Money Laundering (AML) framework, Right Time Trading
has established specific triggers that prompt additional verification processes. These
triggers are designed to detect and prevent suspicious activities by scrutinising high-risk
transactions and customer behaviours thoroughly.
4.1. Additional Verification Triggers
1. High-Value Transactions
– Deposit Thresholds: Any single deposit or a series of deposits exceeding $10,000
triggers additional verification. This includes scrutinising the source of funds and
ensuring compliance with regulatory requirements.
– Large Withdrawals: Similar to deposits, withdrawals exceeding a set threshold, such as
$10,000, prompt further investigation to ensure the funds are legitimate and the
transaction is not part of a money laundering scheme.
2. Unusual Transaction Patterns
– Significant Deviations: Transactions that significantly deviate from a customer’s usual
pattern, such as sudden increases in transaction volume or frequency, trigger a review to
understand the reasons behind the changes.
– Multiple Transactions Just Below Threshold: Multiple transactions that fall just below
the reporting threshold, conducted within a short time frame, indicate potential
structuring activities and trigger additional verification.
3. International Transfers
– High-Risk Jurisdictions: Transfers to or from countries identified as high-risk by
international bodies such as the Financial Action Task Force (FATF) prompt further due
diligence to ensure the legitimacy of the transaction.
– Frequent Cross-Border Transactions: Customers engaging in frequent international
transfers, especially involving high-risk jurisdictions, are subject to enhanced scrutiny.
4. Account Activity
– Dormant Accounts: Sudden activity in dormant accounts, especially involving large
transactions, triggers a review to verify the source and purpose of the funds.
– New Accounts with High Activity: New accounts showing high levels of activity
immediately after opening are reviewed to ensure they are not being used for fraudulent
purposes.
5. Customer Behaviour
– Reluctance to Provide Information: Customers who are hesitant or refuse to provide
required information or documentation during the Know Your Customer (KYC) process
trigger further investigation.
– Third-Party Involvement: Accounts with frequent use of third parties or intermediaries
to conduct transactions prompt additional verification to understand the reasons behind
such activities.
6. Source of Funds and Wealth
– Unusual Funding Sources: Transactions funded from sources that are unusual or not
consistent with the customer’s profile, such as unexpectedly large sums from unknown
sources, trigger further investigation.
– Inconsistent Wealth Declaration: Discrepancies between the customer’s declared
source of wealth and observed transaction behaviour prompt additional due diligence.
4.2. Enhanced Verification Measures
When a trigger is activated, Right Time Trading implements the following enhanced
verification measures:
1. Detailed Transaction Review
– Transaction Analysis: Conduct a detailed review of the transaction(s) in question,
including the source of funds, destination, and the purpose of the transaction.
– Documentation Verification: Request additional documentation to verify the
legitimacy of the transaction, such as invoices, contracts, or bank statements.
2. Customer Profile Update
– Enhanced KYC: Update the customer’s profile with additional information gathered
during the verification process. This includes verifying identification documents, sources
of funds, and business activities.
– Risk Reassessment: Reassess the customer’s risk level based on the new information
and update their risk profile accordingly.
3. Increased Monitoring
– Ongoing Monitoring: Place the customer under increased monitoring for a specified
period to detect any further suspicious activities.
– Transaction Limits: Implement temporary transaction limits or require pre-approval
for large transactions during the monitoring period.
4. Reporting and Escalation
– Suspicious Activity Report (SAR): If the enhanced verification measures raise concerns,
file a Suspicious Activity Report (SAR) with the relevant financial authorities.
– Internal Escalation: Escalate the case to senior management or the compliance
committee for further review and decision-making.
4.3. Examples of Additional Verification Triggers
– Scenario 1: A customer deposits $12,000 in a single transaction. The compliance team
initiates additional verification, requests documentation to verify the source of funds,
and monitors the account for any further high-value transactions.
– Scenario 2: A dormant account suddenly becomes active with multiple transactions
totalling $9,900 each. The compliance team investigates the transactions for potential
structuring activities, requests additional information from the customer, and closely
monitors the account.
5. Example of Risk Assessment in Practice
This area details few practical scenarios to illustrate how Right Time Trading conducts a
risk assessment and implements mitigation measures. These examples demonstrate the
procedures and processes used to identify, assess, and address potential money
laundering risks.
5.1. Example 1: High-Risk Jurisdiction Client
– Scenario: A new client from a country identified as high-risk by the Financial Action Task
Force (FATF) wants to open an account and deposit significant money.
Risk Assessment Process
1. Initial Screening
– The client’s information is screened against international watchlists and databases to
identify any red flags or sanctions.
– The client’s country of origin is flagged as high-risk due to weak AML regulations and
high levels of corruption.
2. Enhanced Due Diligence (EDD)
– Collect detailed information about the client’s identity, including passport, proof of
address, and source of wealth.
– Request documentation to verify the source of the funds, such as bank statements,
business contracts, or proof of income.
3. Risk Scoring
– Based on the collected information, the client is assigned a high-risk score due to the
combination of their jurisdiction and the large deposit amount.
4. Approval Process
– The account opening and deposit require approval from senior management due to
the high-risk score.
– The compliance team reviews all documentation and conducts a thorough
background check.
Mitigation Measures
– Increased Monitoring: The client’s transactions are monitored more closely and
frequently to detect any unusual activity.
– Transaction Limits: Temporary transaction limits are set to manage the risk while the
account is under review.
– Ongoing Review: The client’s account and activity are reviewed periodically to ensure
compliance with AML policies.
Outcome: The client’s account is approved with conditions, including enhanced
monitoring and regular reviews. Any suspicious activity detected during ongoing
monitoring will be reported to the relevant authorities.
5.2. Example 2: Unusual Transaction Patterns
– Scenario: An existing client, who typically makes small, regular deposits, suddenly
begins making large, frequent deposits that deviate from their normal activity.
Risk Assessment Process
1. Transaction Monitoring Alert
– The automated transaction monitoring system flags the unusual deposit pattern for
further investigation.
– An alert is generated for the compliance team to review.
2. Customer Profile Review
– Review the client’s historical transaction patterns and profile information to
understand their typical behaviour.
– Contact the client to inquire about the reasons for the sudden change in deposit
amounts and frequency.
3. Enhanced Due Diligence (EDD)
– Request additional information and documentation from the client to verify the
source of the new funds.
– Analyse the client’s explanation and supporting documents to assess the legitimacy of
the transactions.
– All capital deposited has to be withdrawn in the same method to the same accounts
that the capital is withdrawn from.
4. Risk Reassessment
– Reevaluate the client’s risk score based on the new information and determine if the
changes in behaviour are justified.
Mitigation Measures
– Temporary Hold: Place a temporary hold on large deposits until the source of funds
can be verified.
– Enhanced Monitoring: Increase the frequency and depth of transaction monitoring for
the client’s account.
– Documentation Requirements: Require ongoing submission of documentation for
large deposits to maintain transparency.
Outcome: If the client provides satisfactory explanations and documentation, their risk
score may be adjusted, and the account will continue to be monitored closely. If the
client fails to provide adequate information, further actions such as filing a Suspicious
Activity Report (SAR) or terminating the business relationship may be considered.
Example 3: Politically Exposed Person (PEP)
– Scenario: A new client is identified as a Politically Exposed Person (PEP), holding a highranking government position in a foreign country.
Risk Assessment Process
1. Initial Screening
– The client’s information is screened against PEP databases and watchlists to confirm
their status.
– The client is flagged as high-risk due to their position and potential exposure to
corruption.
2. Enhanced Due Diligence (EDD)
– Collect detailed information about the client’s political role, country of service, and
any known affiliations.
– Request documentation to verify the source of funds and ensure they are not linked
to corrupt activities.
3. Risk Scoring
– Assign a high-risk score to the client based on their PEP status and associated risks.
4. Approval Process
– The account opening and any large transactions require approval from senior
management.
– Conduct a thorough background check and verify all provided documentation.
Mitigation Measures
– Enhanced Monitoring: Implement continuous and enhanced monitoring of the client’s
transactions to detect any suspicious activity.
– Regular Reviews: Conduct regular reviews of the client’s profile and transaction
history to ensure compliance with AML policies.
– Escalation Protocols: Establish clear protocols for escalating any suspicious activities
involving PEPs to senior management and relevant authorities.
Outcome: The client’s account is approved with stringent monitoring and regular
reviews. Any suspicious activity detected during monitoring will be escalated and
reported promptly.
By implementing these detailed risk assessment procedures and mitigation measures,
Right Time Trading effectively manages potential risks associated with high-risk
customers
and transactions, ensuring compliance with AML regulations and maintaining the
integrity of its financial services.
6. Customer Due Diligence (CDD)
1. Customer Identification Program (CIP)
The Customer Identification Program (CIP) is a fundamental component of Right Time
Trading’s Anti-Money Laundering (AML) policy. The CIP is designed to ensure that Right
Time Trading knows the identity of its customers and verifies their identities before
establishing a business relationship. This helps prevent money laundering, terrorist
financing, and other illicit activities.
1.1. Key Components of the CIP
1. Customer Information Collection
– Individual Customers: For individual customers, Right Time Trading collects the
following information:
– Full name
– Date of birth
– Residential address
– Contact information (phone number, email address)
– Nationality
– Government-issued identification number (e.g., passport number, national ID
number)
– Legal Entities: For legal entities (e.g., corporations, partnerships), Right Time Trading
collects the following information:
– The full legal name of the entity
– Type of entity (e.g., corporation, partnership)
– Country of incorporation or registration
– Registered address and principal place of business
– Identification of key management personnel and beneficial owners
– Articles of incorporation or other legal documentation
2. Verification of Identity
– Documentation: Right Time Trading requires customers to provide valid, governmentissued identification documents. For individuals, acceptable documents include
passports, national ID cards, and driver’s licenses. For legal entities, acceptable
documents include certificates of incorporation, business licenses, and legal documents
showing the entity’s structure and ownership.
– Proof of Address: Customers must provide proof of address, such as utility bills, bank
statements, or rental agreements, to verify their residential or business address.
– Electronic Verification: Right Time Trading may use electronic verification methods to
cross-check the provided information against public databases and third-party
verification services.
3. Beneficial Ownership Identification
– For legal entities, Right Time Trading identifies and verifies the beneficial owners,
defined as individuals who ultimately own or control the entity. This includes:
– Obtaining information on individuals who own 25% or more of the entity’s equity.
– Verifying the identity of beneficial owners using the same documentation and
verification standards as for individual customers.
4. Risk-Based Approach
– Risk Assessment: Right Time Trading uses a risk-based approach to determine the
level of due diligence required for each customer. High-risk customers, such as politically
exposed persons (PEPs) and customers from high-risk jurisdictions, undergo enhanced
due diligence.
– Ongoing Monitoring: Customer information is continuously monitored and updated to
ensure it remains current. Changes in a customer’s profile, such as changes in ownership
or address, trigger a re-verification process.
5. Record Keeping
– Retention Period: Right Time Trading maintains records of all customer identification
information and verification documents for at least five years after the end of the
business relationship.
– Accessibility: Records are stored securely and are accessible only to authorised
personnel. They are made available to regulatory authorities upon request.
2. Procedures for Implementing CIP
1. Account Opening Process
– Information Collection: During the account opening process, Right Time Trading
collects the required information from the customer.
– Documentation Submission: Customers are required to submit identification and
proof of address documents.
– Verification: The collected information and documents are verified using manual
checks and electronic verification methods.
2. Enhanced Due Diligence (EDD)
– High-Risk Customers: For high-risk customers, additional information and
documentation are collected. This includes detailed information on the source of funds,
the purpose of the account, and the customer’s business activities.
– Senior Management Approval: High-risk customers and transactions require approval
from senior management before the account can be opened or the transaction
processed.
3. Ongoing Due Diligence
– Periodic Reviews: Customer information is reviewed periodically to ensure it remains
accurate and up-to-date. High-risk customers are subject to more frequent reviews.
– Transaction Monitoring: Ongoing monitoring of transactions helps detect any unusual
or suspicious activity. Transactions that do not align with the customer’s profile trigger
further investigation.
3. Examples of CIP Implementation
3.1. Scenario 1: Individual Customer
– An individual customer wishes to open a trading account with Right Time Trading. The
customer provides their passport a utility bill as proof of address, and completes the
online registration form. Right Time Trading verifies the provided information using both
manual and electronic methods. Once verification is complete, the account is approved,
and the customer can begin trading.
3.2. Scenario 2: Corporate Customer
– A corporate entity wishes to open an account. The entity provides its certificate of
incorporation, a list of directors, and documents identifying the beneficial owners. Right
Time Trading verifies the entity’s information, including the identities of the beneficial
owners. The account is then approved, subject to ongoing monitoring and periodic
reviews.
By implementing a comprehensive Customer Identification Program, Right Time Trading
ensures that it knows its customers and verifies their identities, thereby reducing the risk
of money laundering and other financial crimes.
4. Ongoing Monitoring
Ongoing monitoring is a critical component of Right Time Trading’s Anti-Money
Laundering (AML) policy. This process involves continuously reviewing and analysing
customer transactions and activities to detect and prevent money laundering, terrorist
financing, and other suspicious activities. By maintaining a proactive approach, Right
Time Trading ensures compliance with regulatory requirements and safeguards the
integrity of its financial services.
Key Components of Ongoing Monitoring
1. Transaction Monitoring
– Automated Monitoring Systems: Right Time Trading employs advanced automated
systems to monitor transactions in real time. These systems are configured to detect
patterns, anomalies, and red flags indicative of suspicious activity.
– Transaction Thresholds: Specific thresholds are set for transaction values and
volumes. Transactions exceeding these thresholds trigger alerts for further investigation.
– Pattern Analysis: The monitoring systems analyse transaction patterns over time to
identify unusual or inconsistent behaviours compared to the customer’s historical
activity.
2. Customer Activity Reviews
– Regular Reviews: Customer accounts and transactions are reviewed regularly to
ensure that activities align with the customer’s known profile and the declared purpose
of the account.
– High-Risk Customers: High-risk customers, such as politically exposed persons (PEPs)
and those from high-risk jurisdictions, undergo more frequent and detailed reviews.
– Ad Hoc Reviews: Ad hoc reviews are conducted when unusual activity is detected or
new information about a customer comes to light.
3. Updating Customer Information
– Periodic Information Updates: Right Time Trading periodically requests updated
information from customers to ensure that their profiles remain current and accurate.
This includes verifying contact details, addresses, and beneficial ownership for legal
entities.
– Event-Driven Updates: Updates are triggered by significant events, such as changes in
ownership, large transactions, or unusual account activity.
4. Enhanced Due Diligence (EDD) for High-Risk Activities
– In-Depth Investigations: When high-risk activities or transactions are identified,
enhanced due diligence measures are applied. This involves collecting additional
information and documentation to verify the legitimacy of the activity.
– Senior Management Involvement: High-risk cases are escalated to senior
management for review and approval before proceeding.
5. Suspicious Activity Reporting (SAR)
– Identification of Suspicious Activities: Any transaction or activity that raises suspicion
of money laundering or other illicit activities is flagged for further investigation.
– Filing SARs: If an activity is deemed suspicious after investigation, a Suspicious Activity
Report (SAR) is filed with the relevant financial authorities in compliance with regulatory
requirements.
6. Record Keeping
– Documentation: Detailed records of all monitoring activities, investigations, and
findings are maintained. This includes records of alerts, reviews, and any actions taken.
– Retention Period: Records are kept for at least five years and accessible only to
authorised personnel and regulatory authorities.
5. Examples of Ongoing Monitoring in Practice
5.1. Scenario 1: Unusual Transaction Pattern
– Detection: The automated monitoring system detects large deposits followed by
immediate withdrawals, which is inconsistent with the customer’s usual activity.
– Investigation: The compliance team reviews the transactions and contacts the
customer for an explanation. The customer provides documentation showing the
transactions are related to a legitimate business deal.
– Outcome: After verifying the information, the transactions are deemed legitimate, but
the customer’s account is flagged for ongoing enhanced monitoring to detect any further
unusual activity.
5.2. Scenario 2: High-Risk Customer Review
– Detection: A politically exposed person (PEP) conducts a large international transfer to
a high-risk jurisdiction.
– Investigation: The compliance team initiates an enhanced due diligence process,
including verifying the source of funds and the purpose of the transfer. Additional
documentation is requested from the customer.
– Outcome: The transfer is approved after thorough verification, but the customer’s
account is subject to increased scrutiny, with all future transactions being reviewed by
senior management.
5.3. Scenario 3: Periodic Information Update
– Trigger: A customer’s periodic review is due. The compliance team requests updated
identification documents and proof of address.
– Review: The customer’s information is updated in the system, and their recent
transactions are reviewed to ensure consistency with their profile.
– Outcome: The customer’s profile is updated, and no suspicious activity is detected.
The account continues to be monitored as per standard procedures.
6. Benefits of Ongoing Monitoring
– Early Detection: Enables early detection of suspicious activities, allowing Right Time
Trading to take prompt action to mitigate risks.
– Regulatory Compliance: Ensures compliance with AML regulations and reporting
requirements, reducing the risk of regulatory penalties.
– Customer Protection: Protects customers from fraudulent activities by detecting and
preventing unauthorised transactions.
– Operational Integrity: Maintains the integrity and reputation of Right Time Trading by
proactively managing and mitigating risks associated with financial crimes.
By implementing a robust ongoing monitoring process, Right Time Trading ensures that
customer activities are continuously
scrutinised and potential risks are identified and addressed promptly. This approach not
only enhances compliance with AML regulations but also strengthens the overall security
and integrity of Right Time Trading’s financial services.
7. Reporting Suspicious Activity
Reporting suspicious activity is a critical element of Right Time Trading’s Anti-Money
Laundering (AML) policy. This process ensures that any transactions or behaviours
indicative of money laundering, terrorist financing, or other illicit activities are promptly
identified, documented, and reported to the appropriate authorities. By doing so, Right
Time Trading helps combat financial crime and complies with regulatory requirements.
1. Key Components of Reporting Suspicious Activity
Detection of Suspicious Activity
– Automated Monitoring Systems: Right Time Trading uses sophisticated automated
systems to monitor transactions in real time. These systems are designed to detect
patterns and anomalies that may indicate suspicious activity.
– Manual Review: The compliance team conducts manual reviews in addition to
automated systems to identify unusual or suspicious transactions that may not be
flagged by automated systems.
1. Transaction Red Flags: Large, frequent, or unusual transactions that deviate from the
customer’s typical behaviour, transactions involving high-risk jurisdictions, and complex
or structured transactions designed to evade reporting thresholds.
2. Customer Behaviour Red Flags: Reluctance to provide information, inconsistent or
conflicting information, sudden changes in account activity, and use of multiple accounts
or third parties to conduct transactions.
Internal Reporting Process
– Immediate Action: When suspicious activity is detected, it is immediately reported to
the designated AML compliance officer.
– Documentation: Detailed records of the suspicious activity, including the nature of the
transaction, the parties involved, and any supporting documentation, are compiled.
– Initial Assessment: The compliance officer conducts an initial assessment to determine
whether the activity warrants further investigation or immediate reporting to authorities.
Investigation and Escalation
– Enhanced Due Diligence: Further investigation is conducted to gather additional
information and verify the legitimacy of the suspicious activity. This may involve
contacting the customer for an explanation and requesting additional documentation.
– Senior Management Review: High-risk or complex cases are escalated to senior
management for review and decision-making.
– Legal Consultation: If necessary, legal counsel is consulted to ensure that the
investigation and reporting comply with all applicable laws and regulations.
Filing a Suspicious Activity Report (SAR)
– SAR Preparation: If the investigation confirms that the activity is suspicious and cannot
be adequately explained, a Suspicious Activity Report (SAR) is prepared. The SAR includes
detailed information about the activity, the parties involved, and the reasons for
suspicion.
– Timely Filing: The SAR is filed with the relevant financial regulatory authorities within
the required timeframe, typically within 30 days of detecting the suspicious activity.
– Confidentiality: The process of filing a SAR is kept confidential, and the customer is not
informed about the filing to avoid tipping off potential criminals.
Follow-Up and Monitoring
– Ongoing Monitoring: Accounts associated with filed SARs are subject to increased
scrutiny and ongoing monitoring to detect any further suspicious activity.
– Periodic Reviews: The compliance team conducts periodic reviews of accounts and
transactions to ensure that any additional suspicious activities are promptly identified
and reported.
Record Keeping
– Documentation: All records related to suspicious activity detection, investigation, and
reporting are maintained for a minimum of five years. This includes copies of filed SARs
and any supporting documentation.
– Audit Trail: A comprehensive audit trail is maintained to document the steps taken
during the investigation and reporting process.
2. Examples of Reporting Suspicious Activity
2.1. Scenario 1: Unusual Deposit and Withdrawal Pattern
– Detection: A customer deposits a large sum of money and immediately requests a wire
transfer to an offshore account. This pattern deviates from their usual activity.
– Investigation: The compliance officer reviews the transaction, contacts the customer for
an explanation, and requests additional documentation.
– SAR Filing: The customer’s explanation is unsatisfactory, and the source of funds cannot
be verified. A SAR is filed with the financial regulatory authorities, and the account is
subject to increased monitoring.
2.2. Scenario 2: High-Risk Jurisdiction Transfer
– Detection: An existing customer initiates a large transfer to a high-risk jurisdiction
known for weak AML controls.
– Investigation: Enhanced due diligence is conducted, including verifying the source of
funds and the purpose of the transfer. The customer’s background is also reviewed.
– SAR Filing: The investigation raises further concerns, and the transfer cannot be
justified. A SAR is filed, and the customer’s future transactions are closely monitored.
2.3. Scenario 3: Politically Exposed Person (PEP) Activity
– Detection: A Politically Exposed Person (PEP) makes several high-value deposits from
unknown sources.
– Investigation: The compliance team conducts a thorough review, including checking
international watchlists and verifying the source of funds.
– SAR Filing: The funds’ origins remain unclear, and the transactions appear suspicious. A
SAR is filed, and the customer is informed that their account will be under strict scrutiny.
Reporting Suspicious Activity
– Compliance: Ensures that Right Time Trading complies with AML regulations and avoids
regulatory penalties.
– Risk Mitigation: Helps mitigate the risk of being used as a conduit for money laundering
and terrorist financing.
– Reputation Protection: Protects the reputation of Right Time Trading by demonstrating a
commitment to preventing financial crime.
– Contribution to Global Efforts: Contributes to global efforts to combat money
laundering, terrorist financing, and other financial crimes by providing valuable
information to authorities.
8. Training and Awareness
Training and awareness are critical components of Right Time Trading’s Anti-Money
Laundering (AML) policy. Effective training ensures that employees at all levels
understand their roles and responsibilities in preventing money laundering and terrorist
financing. A well-informed workforce is essential for identifying and reporting suspicious
activities, complying with regulatory requirements, and maintaining the integrity of Right
Time Trading’s financial services.
1. Key Components of the Training and Awareness Program
1. Training Programs
– Mandatory Training: All employees, including new hires, must complete mandatory
AML training as part of their onboarding process and at regular intervals thereafter.
– Role-Specific Training: Customised training programs are developed based on the
specific roles and responsibilities of employees. For example, front-line staff, compliance
officers, and senior management receive training tailored to their functions and risk
exposure.
2. Training Content
– AML Regulations: Training covers the latest AML laws and regulations applicable to
Right Time Trading, including international standards set by bodies such as the Financial
Action Task Force (FATF).
– Company Policies and Procedures: Employees are trained on Right Time Trading’s
internal AML policies, procedures, and controls, including customer due diligence (CDD),
enhanced due diligence (EDD), and ongoing monitoring.
– Red Flags and Indicators: Training includes identifying red flags and indicators of
suspicious activity, such as unusual transaction patterns, high-risk jurisdictions, and
behaviours indicative of money laundering.
– Reporting Procedures: Employees learn the proper procedures for reporting
suspicious activities, including how to complete and submit Suspicious Activity Reports
(SARs) and the importance of maintaining confidentiality.
– Case Studies and Scenarios: Real-life case studies and hypothetical scenarios are used
to illustrate common money laundering techniques and how to effectively respond to
suspicious activities.
3. Delivery Methods
– E-Learning: Online training modules allow employees to complete training at their
own pace. These modules include interactive elements, quizzes, and assessments to
reinforce learning.
– In-Person Training: Workshops and seminars are conducted to provide hands-on
training and facilitate discussions on AML topics. In-person sessions allow for immediate
feedback and clarification of complex concepts.
– Webinars and Videos: Webinars and instructional videos are used to deliver training to
employees across different locations, ensuring consistent messaging and accessibility.
4. Frequency of Training
– Initial Training: New employees complete their initial AML training within the first
month of employment.
– Ongoing Training: Refresher training is conducted annually to ensure employees
remain up-to-date with the latest AML developments and company policies.
– Ad-Hoc Training: Additional training sessions are scheduled as needed in response to
changes in regulations, emerging risks, or identified weaknesses in AML controls.
5. Assessment and Certification
– Knowledge Assessments: Employees are required to complete assessments at the end
of each training module to evaluate their understanding of the material. Passing these
assessments is mandatory for certification.
– Certification: Employees receive certification upon successful completion of their AML
training. This certification is documented and tracked to ensure compliance with
regulatory requirements.
– Performance Reviews: AML knowledge and compliance are incorporated into
employee performance reviews, reinforcing the importance of AML responsibilities.
6. Raising Awareness
– Regular Updates: Employees receive regular updates on AML issues, including
changes in regulations, emerging threats, and best practices. These updates are
disseminated through newsletters, emails, and the company intranet.
– Internal Communications: Ongoing communications from senior management
emphasise the importance of AML compliance and the Company’s commitment to
preventing financial crime.
– Awareness Campaigns: Periodic awareness campaigns, such as AML awareness weeks
or themed events, are organised to keep AML issues top of mind and encourage a culture
of compliance.
7. Monitoring and Evaluation
– Training Effectiveness: The effectiveness of the training program is regularly evaluated
through feedback surveys, assessment results, and monitoring of compliance activities.
– Continuous Improvement: Based on evaluation results, the training program is
continuously updated and improved to address any gaps or areas for enhancement.
– Regulatory Compliance: The training program is reviewed to ensure it meets all
regulatory requirements and aligns with industry best practices.
2. Examples of Training and Awareness in Practice
2.1. Scenario 1: Front-Line Staff Training
– Training Content: Front-line staff, such as customer service representatives, receive
training on identifying red flags during customer interactions, verifying customer
identities, and reporting suspicious activities.
– Delivery Method: An e-learning module followed by an in-person workshop allows
staff to practice identifying and responding to suspicious behaviours through role-playing
exercises.
2.2. Scenario 2: Compliance Officer Training

– Training Content: Compliance officers receive advanced training on conducting
enhanced due diligence, analysing complex transaction patterns, and filing SARs.
– Delivery Method: Webinars featuring industry experts and case studies provide indepth knowledge and practical insights into handling high-risk scenarios.
2.3. Scenario 3: Senior Management Training
– Training Content: Senior management is trained on their oversight responsibilities, the
importance of fostering a culture of compliance, and the strategic implications of AML
policies.
– Delivery Method: A combination of executive briefings and interactive workshops
ensures senior leaders are equipped to support and enforce AML initiatives.
Benefits of a Robust Training and Awareness Program
– Enhanced Detection and Reporting: Well-trained employees are better equipped to
detect and report suspicious activities, reducing the risk of money laundering and
terrorist financing.
– Regulatory Compliance: Comprehensive training ensures that Right Time Trading
complies with AML regulations and avoids potential fines and penalties.
– Reputation Protection: A strong commitment to AML training and awareness helps
protect Right Time Trading’s reputation and build trust with customers, regulators, and
stakeholders.
– Employee Engagement: Ongoing training and awareness initiatives foster a culture of
compliance and accountability, empowering employees to take an active role in
preventing financial crime.
9. Data Integrity Measures
We employ a comprehensive approach encompassing advanced technology, rigorous
policies, and robust procedures to safeguard these records. Below is an overview of our
data integrity measures and encryption practices:
1. Data Encryption
– In-Transit Encryption: All data transmitted over networks is encrypted using industrystandard protocols such as Transport Layer Security (TLS). This encryption prevents
unauthorised interception and ensures that data remains confidential during
transmission.
– At-Rest Encryption: Sensitive data stored in our databases is protected using strong
encryption algorithms, specifically AES-256 (Advanced Encryption Standard with 256-bit
keys). This high-level encryption safeguards data against unauthorised access and
potential breaches.
2. Access Controls
– Role-Based Access Control (RBAC): Access to sensitive data is restricted based on job
roles and responsibilities. This ensures that only authorised personnel have access to
data necessary for their roles, minimising the risk of data exposure.
– Multi-Factor Authentication (MFA): MFA is mandatory for accessing systems that
handle sensitive information, adding an extra layer of security by requiring multiple
forms of verification.
– Audit Trails: Comprehensive audit logs are maintained to record access and actions
performed on sensitive data. These logs ensure accountability and traceability, helping to
detect and respond to unauthorised access.
3. Data Integrity Measures
– Hashing: Critical data elements are hashed to detect any unauthorised changes or
tampering. Regular comparison of hash values ensures that data remains unaltered and
intact.
– Checksum Verification: Files and data transmissions include checksums that are
verified upon receipt. This process ensures that the data has not been corrupted or
altered during transmission.
4. Regular Security Audits and Assessments
– Internal Audits: Regular internal audits are conducted to review data security
practices, access controls, and compliance with internal policies. These audits help
identify potential vulnerabilities and areas for improvement.
– External Audits: Periodic external audits by independent security firms verify the
effectiveness of our security measures and ensure compliance with industry standards.
– Vulnerability Assessments: Routine vulnerability assessments and penetration testing
are conducted to identify and mitigate potential security weaknesses.
5. Data Backup and Recovery
– Regular Backups: Critical data is backed up regularly using secure methods to ensure
that it can be restored in the event of data loss or corruption.
– Disaster Recovery Plan: A comprehensive disaster recovery plan is in place to ensure
business continuity and data integrity in case of system failure or security incidents.
– Redundancy: Data is stored in redundant locations to protect against data loss from
physical damage or system failures.
6. Compliance with Data Protection Regulations
– GDPR Compliance: Right Time Trading adheres to the General Data Protection
Regulation (GDPR) for handling personal data, ensuring that data protection principles
are followed meticulously.
– Data Protection Officer (DPO): Our DPO oversees compliance with data protection
regulations and advises on best practices for data security and privacy.
7. Employee Training and Awareness
– Security Training: Employees receive regular training on data security practices,
including recognising phishing attempts, handling sensitive information, and reporting
security incidents.
– Confidentiality Agreements: All employees and contractors sign confidentiality
agreements as part of their employment contracts, legally binding them to protect
sensitive information.
8. Secure System Design
– Secure Development Practices: Our software development follows secure coding
practices, including regular code reviews and security testing, to ensure the robustness of
our systems.
– Security by Design: Systems and processes are designed with security in mind from
the outset, integrating robust protection measures to safeguard data.
9. Incident Response Plan
– Incident Handling: A formal incident response plan is in place to manage and mitigate
the impact of data breaches or security incidents promptly.
– Reporting and Remediation: Incidents are promptly reported, investigated, and
remediated. Lessons learned from incidents are used to improve security measures
continuously.
10. Third-Party Risk Management
– Vendor Assessments: Thorough assessments of third-party vendors are conducted to
ensure they meet Right Time Trading’s stringent security and confidentiality standards.
– Contracts and SLAs: Contracts with third parties include specific data protection and
security requirements. Service Level Agreements (SLAs) are monitored for compliance to
ensure ongoing adherence to these standards.
10. Record Keeping
Effective record-keeping is a cornerstone of Right Time Trading’s Anti-Money Laundering
(AML) policy. Maintaining comprehensive and accurate records ensures compliance with
regulatory requirements, supports the monitoring and investigation of suspicious
activities, and preserves the integrity of Right Time Trading’s financial operations. Proper
record-keeping facilitates transparency, accountability, and the ability to provide
necessary information to regulatory authorities upon request.
1. Key Components of Record-Keeping
1. Types of Records Maintained
– Customer Identification Records: Documentation and information collected during the
customer due diligence (CDD) and enhanced due diligence (EDD) processes, including
identification documents, proof of address, and beneficial ownership details.
– Transaction Records: Detailed records of all customer transactions, including deposits,
withdrawals, transfers, and other financial activities. This includes the date, amount,
currency, and purpose of each transaction, as well as the parties involved.
– Monitoring and Reporting Records: Records related to the monitoring of customer
activities and transactions, including alerts generated by automated systems,
investigations conducted, and Suspicious Activity Reports (SARs) filed.
– Training Records: Documentation of AML training provided to employees, including
attendance records, training materials, and assessments completed.
– Compliance Reviews and Audits: Records of internal and external audits, compliance
reviews, and any actions taken to address identified issues or weaknesses.
2. Retention Periods
– Minimum Retention Period: All AML-related records must be retained for a minimum
of five years from the date of the transaction or the end of the business relationship,
whichever is later.
– Extended Retention: In cases where an investigation is ongoing, records must be
retained until the investigation is concluded and any regulatory requirements are fully
satisfied.
3. Accessibility and Retrieval
– Secure Storage: Records are stored securely to prevent unauthorised access,
alteration, or destruction. Both physical and electronic records are protected using
appropriate security measures.
– Ease of Retrieval: Records are organised and indexed to ensure they can be easily
retrieved when needed, whether for internal review, regulatory examination, or legal
proceedings.
4. Accuracy and Completeness
– Data Quality Controls: Procedures are in place to ensure the accuracy, completeness,
and reliability of records. This includes regular reviews and updates of customer
information and transaction details.
– Error Correction: Any identified errors or discrepancies in records are promptly
corrected, and measures are taken to prevent recurrence.
5. Confidentiality and Data Protection
– Confidentiality: All AML-related records are treated as confidential and are accessible
only to authorised personnel. Employees are trained on the importance of maintaining
confidentiality and the potential consequences of breaches.
– Data Protection: Compliance with data protection regulations, such as the General
Data Protection Regulation (GDPR), ensures that customer information is handled
responsibly and privacy rights are respected.
6. Audit and Review
– Internal Audits: Regular internal audits are conducted to assess the effectiveness of
the record-keeping processes and identify any areas for improvement. All audit logs are
retained.
– External Audits: Periodic external audits by independent auditors provide an
additional layer of assurance regarding the adequacy and compliance of the recordkeeping system.
7. Regulatory Compliance
– Regulatory Requests: Right Time Trading is prepared to promptly respond to requests
for information from regulatory authorities. This includes providing access to records
related to specific customers, transactions, or investigations.
– Compliance Documentation: Detailed documentation of compliance activities,
including policies, procedures, and records of regulatory interactions, is maintained to
demonstrate adherence to AML regulations.
2. Examples of Record Keeping in Practice
2.1. Scenario 1: Customer Identification Records
– Record Keeping: During the account opening process, a customer provides their
passport, proof of address, and information on beneficial ownership. These documents
are scanned and securely stored in the electronic customer file.
– Retention: The records are retained for at least five years after the business
relationship ends, ensuring they are available for any future regulatory inquiries.
2.2. Scenario 2: Transaction Records
– Record Keeping: A customer makes several large deposits and international transfers.
Each transaction is recorded in detail, including the date, amount, currency, destination,
and purpose of the transfer.
– Monitoring: The transactions are flagged for review due to their size and frequency,
and the compliance team conducts an investigation. All findings and actions taken are
documented and stored.
2.3. Scenario 3: Suspicious Activity Reporting
– Record Keeping: A suspicious transaction is detected, and a SAR is filed with the
relevant authorities. The SAR and all related documentation, including the initial alert
and
investigation notes, are securely stored.
– Confidentiality: The SAR is kept confidential, with access restricted to authorised
personnel only.
2.4. Benefits of Effective Record Keeping
– Regulatory Compliance: Ensures compliance with AML regulations and avoids potential
fines or penalties for record-keeping deficiencies.
– Enhanced Monitoring: Supports ongoing monitoring efforts by providing a
comprehensive record of customer activities and transactions.
– Facilitated Investigations: Enables efficient and thorough investigations of suspicious
activities, ensuring that necessary information is readily available.
– Transparency and Accountability: Promotes transparency and accountability within
Right Time Trading, demonstrating a commitment to preventing financial crime.
– Operational Integrity: Protects the integrity of Right Time Trading’s financial operations
by maintaining accurate and reliable records.
10. Non-Compliance
Employees are expected to adhere to the policies and procedures outlined in this
document and those referenced within it. Should an employee be found in breach of
these policies, they may face disciplinary measures, which could include termination of
employment.
11. Monitoring and Reviewing
Right Time Trading is committed to ensuring our policies are effective and up-to-date. To
do this, we have a process for regularly monitoring and reviewing them. Our Senior
Managers and Directors are responsible for this process and will review the policies at
least once a year or more frequently if needed due to changes in laws or our practices.
12. Monitoring and Reviewing
Right Time Trading is committed to ensuring our policies are effective and up-to-date. To
do this, we have a process for regularly monitoring and reviewing them. Our Directors
are responsible for this process and will review the policies at least once a year or more
frequently if needed due to changes in laws or our practices.