Sword Capital Anti Money Laundering Policy
Money laundering is the common term for the process by which a person seeks to conceal the proceeds of crime by exchanging criminal property for so-called clean money. Activities associated with money laundering include:
• acquiring, using or possessing criminal property;
acquisition of property or assets;
For the purposes of this Manual, the term money laundering will mean money laundering and terrorist financing.
The proceeds of crime or “criminal property” mean any property which constitutes or comes to represent a person‟s benefit from criminal conduct. Criminal property (which also includes “terrorist property”) can take any form: e.g. money, securities, tangible and intangible property, and money, whether or not it is “clean” money, which is used to fund terrorism.
1.2 Money Laundering
Businesses which are seen as likely targets for money launderers wishing to use them as a means to channel the proceeds of crime include: solicitors; accountants; authorized Companies; money services businesses; high value dealers; and trust or company service providers.
There are number of obligations placed on these businesses, such as:
suspicious persons and transactions; and
1.3 The Money Laundering Reporting Officer
The MLRO has overall responsibility within the Company‟s businesses for the establishment and maintenance of effective anti-money laundering systems and