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Home / Anti money laundering and countering financing of terrorism (aml/cft) policy

Policy and Definition

Breder Suasso is committed to be compliant to all legal obligations relating to Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) applicable to a financial institution providing high quality international services.

Breder Suasso considers the New Zealand legislation, in particular, the New Zealand Anti-Money Laundering and Countering Financing of Terrorism Act 2009 (the AML/CFT Act), as a model of serious and robust rules having to be enforced in any circumstances and without any exception.

Beside the New Zealand legislation, Breder Suasso wishes to apply international standards and monitors and adheres to other major international AML/CFT recommendations and programs such as the Financial Action Task Force (FATF), the United Nations and European Union sanctions and the USA Office of Foreign Asset Control (OFAC).

For this purpose, Breder Suasso enforces a strict anti-money laundering and countering financing of terrorism (AML/CFT) policy with zero tolerance for money laundering of financing of terrorism (ML/FT) activities. We define money laundering as any activity that is carried out in an attempt to misrepresent the source of funds actually acquired through illegal processes as funds that were acquired through lawful sources/activities.

The direction, the management and all employees of Breder Suasso are aware that, according to the AML/CFT Act, non-compliance will never be excused by contractual obligations.

The AML/CFT Act has effect despite anything to the contrary in any contract or agreement and no person is excused from compliance with any requirement of the AML/CFT Act or regulations by reason only that compliance with that requirement would constitute breach of any contract or agreement.

All the employees in the service of Breder receive the AML/CFT Program and the time required to read it is given to all employees. Their engagement to apply the AML/CFT Program of Breder Suasso is required in writing ; all employees must indeed sign a confirmation that they have read the AML/CFT Programme and will apply it.

All Breder Suasso affiliates (staff, third party intermediaries, …) are obligated to comply with Breder Suasso’s AML/CFT policy and with all applicable AML/CFT laws. Failure to comply can result in severe consequences such as criminal penalties and heavy fines.

Breder Suasso ensures complete compliance with laws pertaining to AML/CFT through its related policy. At Breder Suasso, for instance, fund transfers related to gambling without a duly obtained license from official government, or any kinds of illegal activity are strictly forbidden. Breder Suasso will immediately stop any such financial activity as soon as it is identified because such activities go against the spirit of Breder Suasso and the principles on which this institution was founded.

Breder Suasso implements a range of filtration operations for swift and accurate identification of any financial activities that may constitute or are related to ML/T. This helps ensure a ML/FT free financial operations throughout the Breder Suasso system.

All Breder Suasso clients acknowledge, undertake and agree to the following terms regarding their use of this website, opening and maintenance of accounts at Breder Suasso and for all financial transactions (including funds transfer, ATM cash withdrawal and debit card use) as a Breder Suasso client:

  1. The client will comply (throughout the time as a Breder Suasso client) with all relevant statutes pertaining to ML/FT.
  2. Breder Suasso operates under certain obligations known as “know-your-client” obligations which grant Breder Suasso the right to implement AML/CFT to help detect and prevent ML/FT activities where ML/FT may mean to handle any funds associated with any illegal activity regardless of the location of such activity.
  3. The client agrees to lend full cooperation to Breder Suasso with respect to ML/FT efforts. This involves providing information that Breder Suasso requests regarding the client’s business details, account usage, financial transactions etc. to help Breder Suasso perform its duties as dictated by applicable laws regardless of jurisdiction.
  4. Breder Suasso reserves the right to delay or stop any funds transfer if there is reason to believe that completing such a transaction may result in the violation of any applicable law or is contrary to acceptable practices.
  5. Breder Suasso reserves the right to suspend or terminate any account or freeze the funds in an account if there is reason to believe that the account is being used for activities that are deemed unlawful or fraudulent.
  6. Breder Suasso has the right to use client information for the investigation and/or prevention of fraudulent or otherwise illegal activities.
  7. Breder Suasso has the right to share client information with:
    (i) Investigative agencies or any authorized officers who are helping Breder Suasso comply with applicable law, including AML/CFT laws and know-your-client obligations;
    (ii) Organizations that help Breder Suasso provide the services it offer its clients;
    (iii) Government, law enforcement agencies and courts;
    (iv) Regulatory bodies and financial institutions;

Risk Assessment

Pursuant to section 58 of the AML/CFT Act, Breder Suasso has undertaken an assessment of the risk of ML/FT that it may reasonably expect to face in the course of its business.

At regular intervals, Breder Suasso’s Board of Directors reviews its risk assessment to ensure it remains current and makes any changes identified as being necessary.

The risk assessment must be audited at least every 2 years.

Activities that Breder Suasso deems ‘Suspicious’

Activities that Breder Suasso considers possible indications of ML/FT include:

  • The client showing unusual apprehension or reservations about Breder Suasso’s AML/CFT policies.
  • The client’s interest in conducting financial transactions which are contrary to good business sense or are inconsistent with the client’s business policy.
  • The client failing to provide legitimate sources for their funds.
  • The client providing false information regarding the source of their funds.
  • The client having a history of being the subject of news that is indicative of civil or criminal violations.
  • The client seems to be acting as a ‘front man’ for an unrevealed personality or business, and does not satisfactorily respond to requests for identifying this personality or business.
  • The client not being able to easily describe the nature of his/her industry.
  • The client frequently makes large deposits and demands dealing in cash equivalents only.
  • The client maintains multiple accounts and conducts an unusually high number of inter-account or 3rd party transactions.
  • The client is a native of, or has accounts in, a country on Financial Action Task Force’s list of Non-Cooperative Countries or Territories.
  • The client’s previously usually inactive account starts receiving a surge of wire activity.

The above list is by no means an exhaustive list; Breder Suasso monitors its client and account activity in light of several other red flags and takes appropriate measures to prevent ML/FT.

  • The client operates non regulated Forex activities involving or not binary options and binary options trading platforms.
  • The client receives cumulative transfers from individuals, unless in the ordinary or normal practice of the declared business.

Client Identification Procedures

Breder Suasso utilizes customer identification procedures to validate the true identity of its clients. Documenting and maintaining these identification procedures enhances Breder Suasso’s ability to prevent ML/FT activities.

Breder Suasso checks among others the person’s details against their customer records, to ensure that no other person has presented the same identity information or documents.

If Breder Suasso fails to verify a client’s identity within an acceptable time period, all services will be suspended for that client and any accounts opened will be terminated. In addition, the account and services attached to that client will be under stricter scrutiny until the suspension and/or closure is carried out.

Identification Procedures for Natural Persons

Breder Suasso requires the following information for natural persons:

  • Legal and other names used such as maiden name
  • Complete permanent address
  • Telephone and fax number
  • Email address
  • Date and place of birth
  • Nationality
  • Occupation details, C.V. or client’s background
  • Any unique identification number from a valid official document bearing a photograph of the client such as ID card, passport or driving license
  • Source of wealth

Identification Procedures for Business Entities

Breder Suasso requires the following information for business entities:

  • Entity’s name
  • Entity’s mailing address
  • Telephone number
  • Any kind of official identification number, if available, such as tax identification number
  • Certificate of Incorporation (original or certified copy)
  • Memorandum and Articles of Association (original or certified copy)
  • Nature and purpose of business
  • Proof of legitimacy of business operations

Breder Suasso verifies the above information via at least one of the following methods:

  • Reviewing the latest audited accounts in case of a corporate entity
  • Utilizing a business information service or attorney to enquire about the entity
  • Conducting commercial enquiries to ensure the entity is a going concern
  • Leveraging independent information verification services e.g. databases
  • Acquiring previous bank references
  • Visiting the corporate entity
  • Contacting the corporate entity using the contact details provided

Any supporting documents can be certified by Breder Suasso employees, Lawyer, Notary, or any approved agent or official introducer who has signed a certification right agreement with Breder Suasso.

Recordkeeping

Breder Suasso keeps all relevant documents and service records for the minimum time as determined by applicable law.

Training

Breder Suasso implements a comprehensive training policy under which it imparts AML/CFT training to every new employee.

As initial training, all the employees in the service of Breder receive the AML/CFT Risk Assessment and the AML/CFT Program and the time required to read it is given to all employees.

Moreover, employees involved in AML/CFT roles are also required to participate in special training programs.

As a result of this comprehensive training policy, all Breder Suasso employees who are tasked with providing Breder Suasso’s services and/or deal with clients (directly or indirectly) are fully aware of all applicable AML/CFT laws and regulations. All Breder Suasso employees are therefore in the ideal position to perform their duties in complete compliance with Breder Suasso’s AML/CFT policy, and with all applicable laws, statutes and regulations.

Administration

An AML/CFT Compliance Board administers the anti-money laundering policy at Breder Suasso. The board’s responsibilities include interpreting, revising and implementing Breder Suasso’s AML/CFT policy.

AML/CFT Compliance Officer
Pursuant to section 56 of the AML/CFT Act, Breder Suasso has designated an AML/CFT Compliance officer to administer and maintain its AML/CFT programme.

Any person concerned may contact the AML/CFT Compliance Officer by sending an email to: compilance@bredersuasso.com