ANTI-MONEY LAUNDERING (AML) POLICY

Money Laundering
i. Transactions with no discernible purpose or are unnecessarily complex.
ii. Use of foreign accounts of companies or group of companies with complicated ownership structure which is not justified based on the needs and economic profile of the Client.
iii. The transactions or the size of the transactions requested by the Client do not comply with his usual practice and business activity.
iv. Large volume of transactions and/or money deposited or credited into, an account when the nature of the Client’s business activities would not appear to justify such activity.
v. The Business Relationship involves only one transaction or it has a short duration.
vi. There is no visible justification for a Client using the services of a particular financial organisation, e.g. the Client is situated far away from the particular financial organisation and in a place where he could be provided services by another financial organisation.
vii. There are frequent transactions in the same financial instrument without obvious reason and in conditions that appear unusual (churning).
viii. There are frequent small purchases of a particular financial instrument by a Client who settles in cash, and then the total number of the financial instrument is sold in one transaction with settlement in cash or with the proceeds being transferred, with the Client’s instructions, in an account other than his usual account.
ix. Any transaction the nature, size or frequency appear to be unusual, e.g. cancellation of an order, particularly after the deposit of the consideration.
x. Transactions which are not in line with the conditions prevailing in the market, in relation, particularly, with the size of the order and the frequency.
xi. The settlement of any transaction but mainly large transactions, in cash.
xii. Settlement of the transaction by a third person which is different than the Client which gave the order.
xiii. Instructions of payment to a third person that does not seem to be related with the instructor.
xiv. Transfer of funds to and from countries or geographical areas which do not apply or they apply inadequately FATF’s recommendations on Money Laundering and Terrorist Financing.
xv. A Client is reluctant to provide complete information when establishes a Business Relationship about the nature and purpose of its business activities, anticipated account activity, prior relationships with financial organisations, names of its officers and directors, or information on its business location. The Client usually provides minimum or misleading information that is difficult or expensive for the financial organisation to verify.
xvi. A Client provides unusual or suspicious identification documents that cannot be readily verified.
xvii. A Client’s home/business telephone is disconnected.
xviii. A Client that makes frequent or large transactions and has no record of past or present employment experience.
xix. Difficulties or delays on the submission of the financial statements or other identification documents, of a Client/legal person.
xx. A Client who has been introduced by a foreign financial organisation; or by a third person whose countries or geographical areas of origin do not apply or they apply inadequately FATF’s recommendations on Money Laundering and Terrorist Financing.
xxi. Shared address for individuals involved in cash transactions, particularly when the address is also a business location and/or does not seem to correspond to the stated occupation (e.g. student, unemployed, self- employed)
xxii. The stated occupation of the Client is not commensurate with the level or size of the executed transactions.
xxiii. Financial transactions from non-profit or charitable organisations for which there appears to be no logical economic purpose or in which there appears to be no link between the stated activity of the organisation and the other parties in the transaction.
xxiv. Unexplained inconsistencies arising during the process of identifying and verifying the Client (e.g. previous or current Hong Kong of residence, Hong Kong of issue of the passport, countries visited according to the passport, documents furnished to confirm name, address and date of birth).
xxv. Complex trust or nominee network.
xxvi. Transactions or Eternal Global Markets Limited structures established or working with an unneeded commercial way, e.g. companies with bearer shares or bearer financial instruments or use of a postal box.
xxvii. Use of general nominee documents in a way that restricts the control exercised by the Zeal Capital Market (Seychelles) Limited’s board of directors.
xxviii. Changes in the lifestyle of employees of the financial organisation, e.g. luxurious way of life or avoiding being out of office due to holidays.
xxix. Changes in the performance and the behaviour of the employees of the financial organisation.