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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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