Anti-Money Laundering (AML) Policy
Money laundering is an offense which most countries, including Thailand, treat as a top priority to combat. Although it is not an offense that causes death, serious injuries or violation of freedom of an individual, it enables organized crimes to cause damages to countries’ economy and security.
Money laundering is the process of making illegally-gained proceeds (i.e. “dirty money”) appear legal (i.e. “clean”). Typically, it involves three steps: placement, layering and integration. First, the illegitimate funds are furtively introduced into the legitimate financial system. Then, the money is moved around to create confusion, sometimes by wiring or transferring through numerous accounts. Finally, it is integrated into the financial system through additional transactions until the “dirty money” appears “clean”.
The Anti-Money Laundering Office was designated by the National Corporate Governance Sub-Committee on Commercial Bank, Securities and Insurance Sectors to chair the working group on Anti-Money Laundering and Combating the Financing of Terrorism (AML-CFT) under the Report on the Observance of Standards and Codes (ROSCs). The working group recognized that the KYC/CDD policies not only help financial institutions detect, deter, and prevent ML-FT, they also are a mandate for action if Thailand wishes to be viewed as compliant with the international standards in AML-CFT.
While COINS TH CO., LTD does not fall within the scope of the AML-CFT obligations in Thailand, the Company has implemented systems and procedures that closely aligned to the Thailand AML legislation. This decision reflects the Company’s desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
Anti-Money Laundering (AML) Policy
COINS TH CO., LTD AML Policy is designed to prevent money laundering by meeting the Thailand 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
COINS TH CO., LTD does not deal with individuals and entities that are engaged in illegal activities or terrorist-related activities as circularized by the AMLO, and other international entities or organizations, such as the Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury and United Nations Sanctions List.