Version 1.0
Prepared by: @Lorraine Sebata
Approved by: @Feli Capron
Reviewed date: 2025-07-25
Next review date: 2026-07-24
This policy outlines Easyterms' commitment to the timely recognition, internal reporting, and external disclosure of suspicious transactions to prevent its services and products from being used for money laundering, terrorist financing, proliferation financing, or any other form of financial crime. It establishes the framework for the roles, responsibilities, and procedures concerning suspicious transaction reporting, ensuring compliance with all applicable laws and regulations, including those concerning the appointment and functions of the Money Laundering Reporting Officer (MLRO) and Compliance Officer (CO).
This policy applies to all employees, agents, contractors, and third parties acting on behalf of Easyterms across all business lines, products, and services. It covers all financial transactions, client relationships, and operational activities that may give rise to suspicion of financial crime.
Easyterms is committed to full compliance with all applicable national and international AML/CTF laws, regulations, and guidelines, including but not limited to those governing suspicious transaction reporting and the appointment of key compliance personnel in The Bahamas.
The Company has appointed a Money Laundering Reporting Officer (MLRO) who is registered with the Financial Intelligence Unit (FIU) and whose registration is on record at the Securities Commission of The Bahamas (SCB). The MLRO is a senior member of staff with the primary responsibility to:
Determine whether information or other matters contained in transaction reports received internally give rise to knowledge or suspicion that someone is engaged in money laundering, terrorist financing, or proliferation financing.
Consider all relevant information available concerning the person or business to whom the initial report relates, including transaction patterns, the business relationship, and identification records held.
Disclose information to the FIU if, after review, the MLRO decides that the initial report gives rise to a suspicion of money laundering or other financial crime.
Have timely access to all customer verification and related due diligence information, transaction records, and other relevant information necessary to perform their duties.
The appointed MLRO is required to meet the following core competencies:
Act honestly and reasonably, making judgments in good faith.
Possess a sound understanding of money laundering and terrorist financing risks specific to the Company.
Have a basic knowledge of The Bahamas' AML/CFT laws and rules.
Be granted sufficient authority and independence to perform their duties effectively.
Be a senior officer within the Company.
Receive annual training in AML/CFT at least once per year.
As required by law, the Company has appointed a Compliance Officer (CO). Due to the size and nature of the services provided, the Company has separated the roles of the MLRO and Compliance Officer. The Compliance Officer is responsible for developing and implementing a compliance work plan which includes:
Ongoing oversight of all legislative and regulatory requirements and the Firm's Policies & Procedures (P&P).
Assisting management in the identification, supervision, and control of risks by ensuring appropriate processes, procedures, and controls are developed and implemented to meet its policies, local laws, and regulatory requirements.
Conducting ongoing tests for the implementation of policies and procedures to ensure compliance, including client onboarding, ongoing monitoring, periodic reviews, and record keeping.
Ensuring the maintenance of proper and adequate records and systems.
Organizing annual anti-money laundering training for all employees handling client transactions.
A suspicious transaction is often one where a transaction is inconsistent with the customer's known, legitimate business or personal activities, or the normal activity within the account. Any unusual transaction will be recognized as potentially suspicious.
All employees are obligated to report any knowledge, suspicion, or reasonable grounds for suspecting money laundering, terrorist financing, proliferation financing, or any financial crime to the MLRO without delay.
If, after investigation by the MLRO, it is reasonably suspected that a customer is engaged in money laundering transactions or proposed transactions involving the proceeds of crime, then as soon as practical, the MLRO must report the transaction or proposed transaction to the FIU.
Employees must not disclose to the client or any third party that a suspicious transaction report has been made or that an investigation is being conducted. Tipping-off is strictly prohibited and carries severe penalties.
All records related to internal suspicious activity reports, MLRO investigations, external Suspicious Transaction Reports (STRs), and related communications with the FIU shall be retained for a minimum period of [e.g., five years] from the date of the report or the end of the business relationship, as required by law.
All relevant employees shall receive regular and comprehensive training on the recognition and internal reporting of suspicious transactions, in addition to general AML/CTF laws, regulations, and internal policies and procedures, commensurate with their roles and responsibilities.
Board of Directors / Senior Management: Overall responsibility for approving and overseeing the AML/CTF program, including policies related to suspicious transaction reporting. Receives reports from the MLRO regarding filed STRs.
Money Laundering Reporting Officer (MLRO): Responsible for the day-to-day oversight of the suspicious transaction reporting process, receiving internal suspicious activity reports, investigating them, and filing STRs with the FIU. Acts as the primary liaison with regulatory bodies concerning STRs.
Compliance Officer (CO): Responsible for developing, implementing, and maintaining the overall compliance framework, including policies and procedures related to AML/CTF and suspicious transaction reporting. Oversees training programs.
All Employees: Responsible for understanding and adhering to this policy, recognizing unusual or suspicious activities, and promptly reporting them to the MLRO.
This policy will be reviewed at least annually, or more frequently if there are significant changes in laws, regulations, business operations, or identified risks related to suspicious transactions.