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Last updated on January 9, 2023
First, it is wise to first offer a tacit definition at the outset as a precis only, with a detailed definition to come below;
“ Money laundering is the illegal process of concealing the origins of money obtained illegally then passing it through a complex sequence of banking transfers or commercial transactions . The overall scheme of this process returns the "clean" money to the launderer in an obscure and indirect way.”
All companies involved to follow those Anti-Money Laundering procedures include “Green Choyce International GmbH”, “Green Choyce”, “Green Vizion International Pte. Ltd.”, “Green Vizion”, “Master Business Warehouses”, “Business Warehouses” and “Partner(s)”. Any of the above used designations concern all the same.
Generally, to secure a solid conviction for Money Laundering, at least two elements must be proved:
1. PROVE the source of Funds were generated from an illegal activity. Such as dealing in illegal Drugs, Funds paid from Blackmail, or derived from Countries that outlaw Pyramid Selling, like Australia, New Zealand, most Countries at Asia except Laos, United Kingdom, Canada, America etc.
2. PROVE the intentional concealing of the Illegal funds. Such as Funds from Pyramid Selling at Singapore produces about USD$500K, then it is advanced as loan to a Mechanical Repair Service Company, as a Capital Loan which is well documented, with a Loan agreement and the Mechanical Services Company repays its Loan Instalments.
The intended Green Choyce International GmbH, (herein after referred to as “Green Choyce") by setting up legitimate structures, is committed to meet worldwide regulatory demands and adhere to current legislative requirements, applicable laws, regulations and worldwide best practices in the area of AML/CTF. Green Choyce will invoke additional Policies and Procedures designed to comply with such legislation, and of course lead by example within its Affiliate Base.
In addition to The Green Choyce Anti-Money Laundering, counter terrorist financing policies and programs set by the Central Bank’s or and other authorities at the various jurisdictions of Green Choyce operations, Green Choyce will cooperate and comply with the requirements set out by global regulators, such as FATF, OFAC, UN and other organizations.
This Policy will be rigidly expected from Green Choyce Shareholders, Employees, Directors, Business Partners, Affiliates and Customers. This shall be accomplished through ongoing and constant training of our staff members, directors and shareholders as well as the constant monitoring and enforcement of the Green Choyce promulgated Code of Ethic’s (COE), wherein this AML Policy shall form part thereof. It shall also be observed during the Adjudication work done at the Green Choyce Complaints Resolution Tribunal (CRT), a function that will fall under the Office of General Counsel for Green Choyce.
This Policy is reviewed and approved by our senior management. We may review this Policy to adhere to new regulatory requirements and global best practices.
1) DEFINITION OF MONEY LAUNDERING AND TERRORIST FINANCING
Money laundering’ means:
1(a) the conversion or transfer of property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person’s actions.
1(b) the acquisition, possession or use of property derived from criminal activity or property obtained instead of such property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation therein.
1(c) the concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property derived from criminal activity or property obtained instead of such property, knowing that such property is derived from criminal activity or from an act of participation in such an activity.
1(d)Terrorist financing’ refers to the processing of funds to sponsor or facilitate terrorist activity. It may involve funds raised from legitimate sources such as personal donations, profits from the businesses and charitable organizations as well as from criminal sources, such as the drug trade, the smuggling of weapons and other goods, fraud, kidnapping, extortion or illegal pyramid Selling, and mass fraud etc.
2) OBJECTIVES OF THE POLICY
- To prevent Green Choyce from being used for financial crime so as to comply with all applicable legal requirements
- To ensure that the most appropriate action is taken by Green Choyce to mitigate the risks associated with financial crime.
- To be the backstop in fostering better learning and understandings from our Affiliates and others mentioned above.
- To portray Green Choyce as the enforcer of AML Laws and never to “side with” nor favor or conceal any AML breaches committed by its Affiliate Account Holders, and to always conduct itself without favor not prejudice.
By creating an account with Green Choyce, or acting as a customer or supplier to Green Choyce, or entering into any transaction with Green Choyce, all Green Choyce account holders, by the opening of their Green Choyce account, shall autonomously be deemed to irrevocably agree as follows:
· You warrant to comply with all applicable anti-money laundering laws and regulations including, but not limited to, the AML/CTF laws and associated rules and regulations as amended from time to time
· You warrant that the money you use to deposit at your account has not been or will not be related to any money laundering or other illegal activities under applicable laws and regulations
· You shall not use the money in your Green Choyce account for the purpose of financing illegal activities
· You agree to promptly notify Green Choyce of any event that is related, or you suspect to be related, to money laundering, terrorist financing or other illegal activities
· You agree to promptly provide us with all information and documents that we reasonably require in order to comply with all applicable laws and regulations relating to anti-money laundering.
· You acknowledge and agree that Green Choyce will conduct initial simplified due diligence and verify your identity and may conduct enhanced due diligence if required by applicable laws and regulations.
· But in any event, whether caused via you fault or others and whether or not was intentionally or unintentionally caused, you herein irrevocably agree to indemnify Green Choyce of all and any responsibility, as the mere conduit of account facilities for your use pursuant to the Green Choyce rules and its COE and other governing statutes.
Green Choyce is obliged to report to the related authority in the event of suspicion of money laundering, terrorist financing or other legal activities and/or transactions. If we believe that a customer commits a suspicious activity and/or transaction, we will file the suspicious transaction report with the related authority in accordance with its relevant procedure, without favor nor prejudice.
4) RISK ASSESSMENT
Green Choyce is committed to identify and assess any money laundering or terrorist financing risks as well as to mitigate these risks to an acceptable level. As part of the risk assessment, we will monitor and review operations of our customers and affiliates.
5) CUSTOMER DUE DILIGENCE
Green Choyce takes steps to identify our customers and check whether they are who they say they are. We may request and obtain the following:
For natural person:
- Full name; and
- Personal identification code; and
- Date and place of birth; and
- Place of residence or seat; and
· If the person is not the customer, the person's relationship to the customer.
For legal person:
- Name or business name of the legal person; and
· registry code or registration number and the date of registration
· names of the director, members of the management board or other body replacing the management board, and their authorization in representing the legal person; and
· name and residence address of beneficial owners
In order to verify the abovementioned information Green Choyce will require the following documents to be submitted:
For a natural person one of the following documents, with photo ID therein:
- Identity card;
- Photo page of passport;
- Diplomatic passport;
· seafarer’s discharge book
· valid travel document issued in a foreign country; or
· driving license that meets legal requirements
For legal entity:
· Certificate of incorporation, memorandum and articles of incorporation or other registration certificate of the relevant register;
· Document confirming a registered address or other relevant document.
If we have any doubts about a customer’s identity, Green Choyce shall reserve the right to require the production of additional documents, and upon failure to deliver the same, Green Choyce reserves the right to not allow the opening if the related Green Choyce account or to terminate whatever business that has transpired, as the case may be.
Where circumstances require, Green Choyce may conduct Enhanced Customer Due Diligence. Such circumstances may be:
a) Upon identification of a person or verification of submitted information, there are doubts as to the truthfulness of the submitted data, authenticity of the documents or identification of the real beneficial owner;
b) The customer is a politically exposed person, except for a local politically exposed person, their family member or a close associate;
c) The customer is from a high-risk third world country or its place of residence or seat or the seat of the payment service provider of the payee is in a high-risk third world country;
d) The customer is from such country or territory or its place of residence or seat or the seat of the payment service provider of the payee is in a country or territory that, according to credible sources such as mutual evaluations, reports or published follow-up reports, has not established effective AML/CFT systems that are in accordance with the recommendations of the FATF, or that is considered a low tax rate territory;
e) Any other situation where there is a higher risk of money laundering as defined by applicable laws and regulations
f) Any other circumstances that warrants concern in the discretion of Green Choyce
The enhanced due diligence measures for customers in high-risk third country include
a) gathering additional information about the customer and its beneficial owner
b) gathering additional information on the planned substance of the business relationship
c) gathering information on the origin of the funds and wealth of the customer and its beneficial owner
d) gathering information on the underlying reasons of planned or executed transactions
e) receiving permission from the senior management of Green Choyce to establish or continue a business relationship
f) improving the monitoring of a business relationship by increasing the number and frequency of the applied control measures and by choosing transaction indicators that are additionally verified
g) demanding a customer make a payment from an account held in the customer’s name in a credit institution
The enhanced due diligence measures when we deal with a politically exposed person are:
a) obtaining approval from the senior management of Green Choyce to establish or continue a business relationship with the person and making sure that only senior management of Green Choyce gives approval for a new business relationship in written form
b) applying measures to establish the origin of the wealth of the person and the sources of funds that are used in the business relationship or upon making occasional transactions
c) monitoring the business relationship in an enhanced manner
Green Choyce will send a questionnaire on funds origin to the customer if such customer wishes to make a transaction in the amount exceeding USD10,000 or other equivalent. Then such completed questionnaire shall be provided and supported documentation on funds origin in order to complete the transaction.
6) MONITORING CUSTOMER ACTIVITY
Green Choyce conducts ongoing monitoring of customer activity in order to:
a) identify any unusual activity, flagging up transactions/activities for further examination;
b) check transactions made in a business relationship in order to ensure that the transactions are in concert with the obliged entity’s knowledge of the customer, its activities and risk profile;
c) regularly update relevant documents, data or information gathered in the course of application of due diligence measures;
d) identify the source and origin of the funds used in a transaction;
e) pay more attention to high-risk transactions.
Green Choyce’s ongoing monitoring of customer activity comprises:
a) “Real-time” monitoring of activities/transactions as they arise or are about to take place;
b) “Post-event” monitoring within defined parameters.
7) ANTI-MONEY LAUNDERING (AML) POLICY AND PRINCIPLES
We have set these minimum standards and principles:
a) Establishing and maintaining a Risk Based Approach towards assessing and managing the money laundering and terrorist financing risks to the company;
b) Establishing and maintaining risk-based customer due diligence, identification, verification and know your customer procedures, including enhanced due diligence;
c) Establishing and maintaining risk based systems and procedures to monitor on-going customer activity;
d) Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
e) Maintenance of appropriate records for the minimum prescribed periods;
f) Training and awareness for all relevant employees and Affiliates.
8) SANCTIONS POLICY
Green Choyce is prohibited from transacting with individuals, companies and countries that are on prescribed sanctions lists. Green Choyce will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.
9) ANTI-BRIBERY AND ANTI-FRAUD
Green Choyce will not tolerate any form of bribery, corruption and/or fraud. All Green Choyce employees are strictly prohibited from having any involvement in the act of such activities. Any non-compliance to this provision shall lead to disciplinary action.
10) DATA RETENTION
Green Choyce will retain documents related to identification information which serve the basis for identification and verifications of persons, and the documents serving as the basis for the establishment of a business relationship as well as certain other documents and information as per AML laws and regulations no less than ten (10) years after termination of the business relationship.
DATED on May 9, 2022
Duly Sanctioned by:
Green Choyce International Management