Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Export Credit Financial Services

1. Introduction

Export Credit Financial Services is committed to maintaining the highest standards of integrity, transparency, and compliance in all financial activities. As a financial services provider engaged in export finance, microfinance, trade facilitation, and financial advisory services, the company recognizes the importance of preventing money laundering, terrorist financing, and other financial crimes.

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy establishes the procedures and controls implemented by Export Credit Financial Services to identify, prevent, detect, and report suspicious financial activities. The policy reflects the company's commitment to complying with applicable financial regulations and international standards for combating money laundering and terrorist financing.

2. Purpose of the Policy

The purpose of this policy is to:

  • Prevent Export Credit Financial Services from being used for money laundering or terrorist financing.
  • Establish procedures for identifying and verifying clients.
  • Ensure compliance with applicable Anti-Money Laundering laws and regulations.
  • Protect the integrity and reputation of Export Credit Financial Services.
  • Promote transparency and accountability in financial transactions.

3. Scope of the Policy

This AML & KYC Policy applies to:

  • All directors, officers, employees, consultants, and representatives of Export Credit Financial Services.
  • All clients, partners, and counterparties engaging in financial transactions with the company.
  • All financial services offered by the company, including export financing, microfinance lending, trade facilitation, and advisory services.

4. Regulatory Compliance

Export Credit Financial Services is committed to complying with all applicable Anti-Money Laundering and Counter-Terrorism Financing regulations, including international guidelines issued by organizations such as:

  • Financial Action Task Force (FATF)
  • International Anti-Money Laundering standards
  • Applicable national financial regulatory authorities
  • Relevant financial intelligence units (FIU)

The company maintains internal controls to ensure compliance with these regulatory requirements.

5. Definition of Money Laundering

Money laundering refers to the process of disguising the illegal origin of funds obtained through criminal activities so that they appear to come from legitimate sources. It generally occurs in three stages:

Placement — The introduction of illegal funds into the financial system.

Layering — The process of separating illicit funds from their source through complex transactions.

Integration — The reintroduction of the laundered funds into the legitimate financial system.

Export Credit Financial Services takes measures to detect and prevent activities related to all stages of money laundering.

6. Know Your Customer (KYC) Procedures

Export Credit Financial Services conducts thorough customer due diligence procedures before establishing any business relationship.

Customer Identification

Clients must provide valid identification documents including:

For Individuals:

  • Government-issued identification
  • Proof of residential address
  • Contact information
  • Source of income

For Businesses:

  • Certificate of incorporation or business registration
  • Business license
  • Company ownership structure
  • Identification of directors and shareholders
  • Corporate bank account details
  • Tax registration documents

7. Customer Due Diligence (CDD)

The company performs Customer Due Diligence to verify the identity of clients and assess the risks associated with each client relationship.

CDD procedures include:

  • Verification of customer identity
  • Identification of beneficial owners
  • Understanding the nature of the client's business
  • Assessment of transaction patterns
  • Determination of the purpose of the business relationship

8. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be required for higher-risk clients, including:

  • Politically Exposed Persons (PEPs)
  • High-risk jurisdictions
  • Large or unusual transactions
  • Complex corporate structures
  • Clients operating in high-risk industries

EDD measures may include additional documentation, background checks, and enhanced monitoring of financial transactions.

9. Ongoing Monitoring of Transactions

Export Credit Financial Services continuously monitors client transactions to ensure they are consistent with the client's business activities and risk profile.

Monitoring includes:

  • Reviewing transaction patterns
  • Identifying unusual or suspicious activities
  • Monitoring large or complex transactions
  • Ensuring transactions align with declared business activities

10. Suspicious Activity Reporting

Employees of Export Credit Financial Services must report any suspicious activity that may indicate money laundering, terrorist financing, or financial crime.

Examples of suspicious activities include:

  • Unusual transaction patterns
  • Transactions inconsistent with the client's profile
  • Use of multiple accounts to obscure transaction origin
  • Reluctance to provide identification documents

Where necessary, Export Credit Financial Services will report suspicious activities to the appropriate financial authorities or financial intelligence units in accordance with legal obligations.

11. Record Keeping

Export Credit Financial Services maintains records of all client identification documents, financial transactions, and due diligence information for a minimum period required by applicable regulations.

Records may include:

  • Customer identification documents
  • Transaction records
  • Due diligence documentation
  • Suspicious activity reports

These records are maintained securely and confidentially.

12. Staff Training

Export Credit Financial Services provides training to employees to ensure they understand their responsibilities in preventing money laundering and terrorist financing.

Training programs include:

  • AML compliance awareness
  • KYC procedures
  • Identification of suspicious activities
  • Reporting procedures

Employees are required to adhere strictly to AML and KYC compliance requirements.

13. Internal Controls and Compliance

Export Credit Financial Services implements internal systems and procedures to ensure compliance with AML and KYC regulations.

These controls include:

  • Internal compliance monitoring
  • Risk assessment procedures
  • Periodic compliance reviews
  • Documentation and audit processes

The company may appoint a compliance officer responsible for overseeing AML and KYC implementation.

14. Confidentiality

All information collected during KYC and AML procedures is treated as confidential and used solely for compliance, regulatory, and legitimate business purposes.

Employees must not disclose confidential information to unauthorized parties.

15. Non-Compliance

Failure by employees or clients to comply with AML and KYC requirements may result in:

  • Termination of business relationships
  • Reporting to regulatory authorities
  • Disciplinary action against employees
  • Legal proceedings where applicable

16. Policy Review

This AML and KYC Policy will be reviewed periodically to ensure compliance with regulatory requirements and international best practices.

Export Credit Financial Services reserves the right to update or modify this policy as necessary.

17. Commitment

Export Credit Financial Services is committed to maintaining a strong compliance culture and to supporting international efforts to combat money laundering, financial crime, and terrorist financing. The company will continue to strengthen its internal controls and procedures to ensure transparency, accountability, and responsible financial operations.