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Bilbow Investment Companies AML /STF Policy
The Bilbow Investment Company AML Policy is designed to ensure that all our firms comply with the requirements and obligations set out in the United Kingdom and international legislations, regulations, rules and Industry Guidance for the financial services sector, including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. The AML Policy sets out the minimum standards which must be complied with by all Bilbow Investment Companies and employees and includes:
- The appointment of a Compliance Officer who has responsibility for the oversight of compliance with relevant legislation, regulations, rules and industry guidance;
- Establishing and using a risk-based approach towards assessing and managing the money laundering and terrorist financing risks to the Group;
- Establishing and maintaining risk-based customer due diligence, identification, verification (ID&V) and know your customer (KYC) procedures, including enhanced due diligence (EDD) for those customers presenting higher risk, such as Politically Exposed Persons (PEPs) and Correspondent Banking relationships;
- Establishing and using a risk-based systems and procedures to monitor ongoing customer activity;
- Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;
- Procedures for reporting suspected fraudulent use of identification documents to the relevant law enforcement authorities as appropriate;
- The maintenance, storage and back-up of appropriate records for the minimum prescribed periods;
- Continuous training and awareness for all relevant employees;
- And the provision of appropriate management information and reporting to senior management of the Group’s compliance with the requirements.
Bilbow Investment Companies AML /STF Policy
- To comply with the relevant Anti-Money Laundering and Counter-Terrorist Financing regulations, we require all our clients to provide identification for account verification. Documents accepted as proof of ID:
- Passport
- Government-issued photo ID
- Driver’s Licenses
All ID documents should display:
- Your full name
- Date of birth
- Your photo
- Date of issuance (within the last 10 years)
- Date of expiry (if applicable)
- All pages should be clear and visible.
Documents accepted as proof of residence:
- Utility bill
- Bank statement
- Government issued letter or notice
Corporate Accounts
- A copy of the memorandum and articles of association;
- A copy of the certificate in incorporation;
- Latest copy of the most recent accounts;
- Proof of registered address (recent annual return or print out from the company registry);
- Proof of trading (postal) address if different to registered address (recent copy of bill or bank statement showing the company’s name and business address);
- Recent bank statement confirming the bank details that will be used to fund the account;
- Copy of register of shareholders or partners as well as verification of the identity of all shareholders and / or partners with a holding of 25% or more;
- Individual shareholders would also need to provide
- a copy of passport and;
- a recent copy of residential utility bill being no more than 3 months old.
- shareholders with a shareholding of 25% or more is corporate entity, then all the above applies to each entity too;
- Identification and address verification of two directors or partners;
- Full name, address and date of birth of the authorized signatories. If an authorized signatory is not a director then a Power of Attorney signed by a director authorizing the individual(s) to operate the account will need to be supplied.