Elmwood Property Group LTD Anti-Money Laundering (AML) Policy Statement 2024

Elmwood Property Group LTD is committed to preventing money laundering and terrorist financing in accordance with applicable laws and regulations. To meet this commitment, Elmwood Property Group LTD has established this Anti-Money Laundering Policy Statement. 

 

Purpose: 

• The purpose of this policy is to prevent money laundering and terrorist financing activities by establishing a comprehensive AML program in accordance with applicable laws and regulations. 

 

Responsibilities: 

• Elmwood Property Group LTD’s management is responsible for implementing and maintaining an effective AML program. 

• All employees are responsible for understanding the AML policy and their role in its implementation. 

• Elmwood Property Group LTD’s AML Officer is responsible for overseeing the AML program and ensuring its effectiveness. 

 

AML Program Requirements: 

• Customer identification and due diligence procedures 

• Suspicious activity monitoring and reporting 

• Internal controls and audit procedures 

• Training and education for employees 

• Independent review and testing of the AML program 

 

Customer Identification: 

• Elmwood Property Group LTD will implement customer identification procedures to verify the identity of its customers before entering into a business relationship. 

• Customer identification information will be kept confidential and protected. 

 

Suspicious Activity Monitoring: 

• Elmwood Property Group LTD will establish and implement procedures for monitoring transactions for suspicious activity. 

• If any suspicious activity is detected, Elmwood Property will take appropriate action, including filing a Suspicious Activity Report (SAR) with the relevant authorities if required. 

 

Internal Controls and Audit: 

• Elmwood Property Group LTD will establish and maintain internal controls to ensure the effectiveness of its AML program. 

• The AML program will be subject to independent review and testing on a regular basis. 

 

Training and Education: 

• All employees will receive AML training to understand the requirements of the AML policy and their role in its implementation. 

• Training will be provided on a regular basis to ensure that employees are kept up-to-date on changes in the AML landscape. 

This Anti-Money Laundering Policy Statement will be reviewed and updated as necessary to ensure its effectiveness and compliance with applicable laws and regulations.