Anti -Money Laundering (AML) Policy
Effective Date: October 26, 2023 Version: 1.1
1. Applicability
This policy applies to all entities under Casantey Business Solutions Group Limited (“Casantey” or “the Group”), including subsidiaries, affiliates, employees, contractors, and agents operating globally.
2. Introduction
Casantey is committed to upholding the highest ethical standards and ensuring compliance with all applicable anti-money laundering (AML) and counter-terrorist financing (CFT) regulations. This policy establishes a structured approach to preventing, detecting, and reporting money laundering and terrorist financing activities within the Group.
3. Policy Objectives
The objectives of this AML policy are to:
• Prevent Casantey's services from being exploited for money laundering or terrorist financing.
• Ensure compliance with all applicable AML/CFT laws and regulations in Ghana and other jurisdictions where Casantey operates.
• Establish a robust AML/CFT compliance framework.
• Provide comprehensive training and awareness programs for employees.
• Foster a culture of compliance and integrity within the organization.
• Protect Casantey’s reputation and safeguard its business interests.
4. Legal and Regulatory Framework
Casantey’s AML program is based on the following legal and regulatory instruments (as amended from time to time):
• Ghana’s Legal Framework:
o The Anti-Money Laundering Act, 2020 (Act 1044).
o The Anti-Terrorism Act, 2008 (Act 760).
o Regulations issued by the Bank of Ghana (BoG).
• International Standards & Best Practices:
o Recommendations from the Financial Action Task Force (FATF).
o Sanctions and regulatory requirements of relevant jurisdictions where Casantey operates.
5. Risk-Based Approach (RBA)
Casantey adopts a risk-based approach (RBA) to AML compliance. This approach ensures that the level of scrutiny applied to customers, transactions, and business activities is proportionate to their assessed risk. Key elements include:
• Conducting regular risk assessments to identify and mitigate money laundering risks.
• Applying enhanced scrutiny to high-risk customers, transactions, and industries.
• Adjusting monitoring mechanisms based on evolving risks and regulatory updates.
6. Customer Due Diligence (CDD)
Casantey implements strict Customer Due Diligence (CDD) procedures, including:
• Know Your Customer (KYC):
o Verifying customer identities using reliable and independent sources.
o Identifying beneficial owners of legal entities.
•Enhanced Due Diligence (EDD):
o Applying additional scrutiny to Politically Exposed Persons (PEPs), high-risk industries, and customers from high-risk jurisdictions.
• Ongoing Monitoring:
o Reviewing customer transactions for unusual or suspicious activities.
o Maintaining updated risk profiles based on customer behaviour.
7. Transaction Monitoring & Suspicious Activity Reporting (SAR)
Casantey utilizes an automated transaction monitoring system to detect red flags, such as:
• Unusual transaction patterns, large cash deposits, or rapid fund movements.
•Transactions inconsistent with a customer’s profile or business operations.
• Payments linked to high-risk jurisdictions or sanctioned entities.
Suspicious Activity Reporting (SAR):
• Employees must report any suspicious activity to the AML Compliance Officer immediately.
• The Compliance Officer will file Suspicious Transaction Reports (STRs) with the Financial Intelligence Centre (FIC) of Ghana or relevant authorities as required.
8. Record Keeping & Retention
Casantey will maintain comprehensive records, including:
• Customer identification and verification documents.
• Transaction records and communications related to high-risk transactions.
• Internal investigations and SAR filings.
• Retention Period: Records will be retained for a minimum of five (5) years or as required by applicable laws.
9. Training & Awareness
Casantey will conduct mandatory AML training for all employees and contractors. Training will cover:
• AML/CFT regulations and compliance obligations.
• Identifying suspicious activities and red flags.
• Reporting procedures and whistleblower protections.
Training programs will be updated annually to reflect evolving risks and regulatory changes.
10. Independent Audit & Compliance Oversight
• Casantey’s AML program will undergo independent audits periodically to assess effectiveness and compliance.
• Findings and recommendations will be addressed promptly to enhance AML controls.
11. AML Compliance Officer
Casantey will appoint a dedicated AML Compliance Officer, responsible for:
• Implementing and enforcing AML policies and procedures.
• Conducting risk assessments and compliance reviews.
• Reporting to senior management and regulatory authorities on AML matters.
12. Sanctions Compliance
Casantey will comply with global sanctions programs, including:
• United Nations (UN) Sanctions
• United States (OFAC) Sanctions
• European Union (EU) Sanctions
Any other applicable sanctions regimes
Transactions involving sanctioned individuals, entities, or countries will be blocked and reported to the relevant authorities.
13. Whistleblower Protection
Casantey maintains a zero-tolerance policy for retaliation against employees who report AML violations in good faith. Employees are encouraged to report concerns confidentially and anonymously through designated channels.
14. Consequences of Non-Compliance
Failure to comply with this AML policy may result in:
• Disciplinary action, including termination of employment or contract.
• Regulatory penalties imposed by government agencies.
• Criminal liability where applicable.
15. Communication & Accessibility of Policy
• This policy will be made available to all employees, contractors, and agents via Casantey’s intranet and official communication channels.
• The AML Compliance Officer will ensure regular policy updates and communication.
16. Contact Information
For questions or concerns related to this policy, contact: AML Compliance Officer:
Email: compliance@casanteyworld.com