For the most part, CrossBorder’s anti-money laundering and counter-terrorist financing (AML/KYC) policy serves the function of setting out the broad ground rules (TF). ML/TF risk is well-controlled and limited by CrossBorder’s comprehensive procedures, including the proper ways. In order to prevent money laundering or terrorist financing, CrossBorder’s values demand all employees, management, and subsidiaries comply to strict anti-money laundering/countering terrorism (AML/CFT) compliance standards. KYC documents are required by CrossBorder to authorise you for any account, whether it’s an IBAN account, a card processing solution or an APM’s. Having this information at the time we submit your documents for verification provides us an advantage. When it comes to CrossBorder, our merchants can rest easy knowing that we’ve got their backs.
The Board of Directors and CrossBorder Local Legislative Structure Anti-Money Laundering, its Amendments, and Executive Regulations must approve any significant changes to CrossBorder’s AML policy. KYC rules issued by CrossBorder LLC and AML/CFT Regulations for companies published by CrossBorder LLC have been substantiated by justifiable reasons for examining unusual and suspicious transactions reported to the Department. In the case of money laundering, terrorist financing, or any other type of money laundering, CrossBorder notifies these transactions to CrossBorder LLC For AML/CFT rules and internal controls, we conduct off-site as well as on-site supervision of all firm branches & subsidiaries. AML/CFT training plans for the company’s employees are set in coordination with the Human Resources Department (HR). We propose training programmes essential to carry out these projects and monitor their implementation. At least once a year, our AML/CFT actions are reported to the MLRO in a periodic report. CrossBorder LLC receives the information once the MLRO has reviewed it, commented on it, and taken any appropriate steps.
In order to comply with KYC and anti-money laundering rules, it is critical to identify customers at the beginning of a commercial relationship. The following key principles underpin the process of identification: Original documents must be used by each and every customer (or member of a legal entity in this situation). These records will be kept in a single location. Customer background, country of origin, public or high-profile position, connected accounts, business activity or other risk indications will be checked by CrossBorder. Transactions done by professional intermediates; any individual or organisation linked to a financial transaction can pose major reputational or operational hazards. Keeping records up-to-date and relevant is essential. The corporation should cancel the account and return the funds to the source account if verification issues occur in the business relationship that cannot be resolved. We will never open an account or do business with anyone who requests anonymity or provides a false identity. All individuals identifiable by our IT system must be registered. If the KYC process is not completed, a person or entity will not be considered a customer.
As a result, CrossBorder guarantees that the sales department has a thorough understanding of the customer’s KYC, KYB, and the level of risk they pose to the company. Our company will be able to avoid any potential money laundering or terrorism financing transactions if we use this method. As part of CrossBorder’s screening process, the company ensures that all customer data and documents uploaded to the system are correct and genuine. Using CrossBorder’s risk-based methodology in categorising clients to risk criteria, values meet legal and regulatory obligations. (Low/Medium/High) Degree of Risk.
CrossBorder will conduct a risk-based approach assessment on a regular basis to ensure that customer-related data or information for some specialised higher-risk customer categories remains current.The existing KYC review approach for other customer groups is mostly based on a “awareness principle” after the AML team has examined an actual file.This approach entails asking the customer’s account manager to do a KYC evaluation of customer service on a regular basis.
The AML and compliance team guarantees that “ongoing transaction monitoring” is carried out to identify anomalous or suspicious transactions when compared to the customer profile.
CrossBorder will keep track of transactions on two levels.
The Front Line of Defence: CrossBorder alerts its network to the possibility of suspicious transactions, so that any communication with a client, account holder, or authorised agent triggers the application of due diligence to transactions on the account in question.These include, for example,Requests for the account’s financial transactions to be completedClaims relating to payment methods or account servicesDue diligence must also be applied to the specific transactions provided to the customer success team member, maybe through their Compliance Manager. The character of one or more transactions is essentially determined by a subjective customer assessment (KYC), financial behaviour, and transaction counter-party. Atypical transactions are those observed on client accounts for which it is difficult to determine the legal activity and source of funds (as they are not directly justifiable). Any CrossBorder employee who notices anomalous transactions that they cannot link to a lawful activity or source of income attributed to the customer must report them to the AML division.
Sanction’s screening: CrossBorder has implemented a list matching mechanism to compare the names of its clients with official lists from CrossBorder LLC, the EU, OFAC, and the UN in order to assure compliance with the applicable sanctions. Additionally, transactions with foreign banks are matched through an internet system to ensure compliance with sanctions commitments.
In addition to the above, CrossBorder internally edits and maintains a Country Watchlist with the following authority to offer all business lines with up-to-date information on jurisdictions under embargo
CrossBorder’s compliance management programme includes risk assessment as a key component.As part of its risk-based approach, CrossBorder conducted an AML “Enterprise - wide risk assessment” to identify and evaluate risks unique to the company and its business lines. The Principles of ExcellenceAfter identifying and documenting the risks associated with the company’s business lines, such as the products and services it provides, the AML risk profile will be determined. Customers to whom such items and services are offered, transactions conducted by these customers, distribution channels employed by the company, geographic locations of the company’s activities, customers, and revenues, and other qualitative and developing hazards. CrossBorder of regulatory requirements, regulatory expectations, and industry guidelines will be used to categorise AML/CFT risk categories.
A “Compliance” risk profile is calculated upon entering into relations (Low, Medium, High) and will be recalculated based on the risk in order to assist and define the level of AML/CFT due diligence to be conducted in relation to a client.
KYC may necessitate the examination of documents in order to verify the authenticity of an address and biometric identification.
Protection Guarantee: Employees who report questionable transactions – in good faith – will be protected by the company.
Internal control of organisation
Reporting of suspicious transactions: CrossBorder explains in detail the terms and instructions for its staff members when it is essential to make a report and proceed with it. The AML team at CrossBorder will conduct a thorough review of the transactions in accordance with the processes in place.
CrossBorder LLC’s AML team will assess if it is essential to send a report to the FIU based on the results of this investigation and the information acquired.
There is no limit on the volume or type of transactions that must be reported, regardless of whether they are suspected of being money laundering or terrorism financing.
There will be a full explanation as to what sparked the company’s suspicion.
It is CrossBorder’s responsibility to produce a report in the format defined by CrossBorder LLC The CrossBorder form should include all relevant details and copies of the suspicious transaction.
Data relating to transactions suspected of being money laundering or terrorist financing must not be given to the client, beneficial owner, or any other entity except to the authorities and entities responsible for enforcement of Anti-Money Laundering Law.
On the CrossBorder Intranet portal, the AML/CFT requirements, including minimum KYC standards, have been turned into operational guidelines or procedures.
For a period of five years, CrossBorder will keep the following documentation:
Unusual transaction reports and documentation are proving that they have been reviewed.
The suspicious transactions will be kept by CrossBorder, which will contain copies of suspicious transaction documents (originals will be kept with the company’s records at the Archive), as well as copies of reports filed to CrossBorder LLC Copies of documents and reports that the Compliance Department’s Head has chosen to maintain.
Records of training programmes must include information on all AML/CFT programmes presented to the company’s employees, trainees’ names, divisions/departments, content, training programme duration, and training entity, whether domestic or international.
Training and awareness programmes have been implemented by CrossBorder to keep its employees aware of their AML/CFT responsibilities. In its use, the program’s training and awareness programme can be seen. Following the most recent regulatory changes, mandatory AML e-learning classes.
As a result, CrossBorder is available to help reduce your financial crime risk while adhering to all AML and compliance rules. For our clients, we’d like to take as much of the compliance burden off their shoulders as possible. While we can’t do everything, we will give it our best effort. If we are unable to assist you, please contact our customer care staff.
With CrossBorder as your consultant, you can rest assured that you are adhering to all AML, BSA, and compliance requirements. Alternatively, you can start with the CrossBorder documentation.