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Anti Money Laundering Policy

The Metropolitan Forex bureau AML Policy is designed to prevent money laundering

Introduction

Metropolitan Forex Bureau LTD was established in 1990. We are a money changing company dealing in the buying and selling of all major foreign currencies. We offer money remittance services globally through; MoneyGram, Western Union, and Xpress Money, We also do wire transfers in all major currencies.

Our business is focused on money changing and throughout the years. We have expanded our operations and services in Kampala City and in Entebbe.Among all the licensed Forex bureaus in Uganda, Metropolitan Forex Bureau (U) Ltd offers the best currency exchange rates on the days market plus faster service. Metropolitan FX Bureau has provided services to many well-known and established corporations, NGOs, companies and institutions in Uganda and also to hundreds satisfied local individuals and foreign tourists as well.

Definition of Key Terms & Abbreviations Used in the AML Policies

Metropolitan Forex Bureau Ltd. is committed to the highest standards of anti-money laundering (AML) and counter-terrorism financing (CFT) and requires the management and employees to follow the named standards. Metropolitan Forex Bureau examines its AML strategies and objectives on an ongoing basis, and maintains an effective AML policy that reflects its best practices as a domestic financial services provider. The Metropolitan Forex Bureau AML program includes appropriate KYC and Customer Acceptance policies, including establishing the identity of the true beneficial owners, adherence to all legal and regulatory requirements imposed by the government and its regulators.

Money laundering

the process of converting funds, received from illegal activities (such as fraud, corruption, terrorism, etc.), into other funds or investments that look legitimate to hide or distort the real source of funds.

The process of money laundering can be divided into three sequential stages:
Placement:

At this stage, funds are converted into financial instruments, such as checks, bank accounts, and money transfers, or can be used for purchasing high-value goods that can be resold. They can also be physically deposited into banks and non-bank institutions (e.g., currency exchangers). To avoid suspicion by the company, the launderer may as well make several deposits instead of depositing the whole sum at once; this form of placement is called smurfing

Layering:

Funds are transferred or moved to other accounts and other financial instruments. It is performed to disguise the origin and disrupt the indication of the entity that made the multiple financial transactions. Moving funds around and changing in their form makes it complicated to trace the money being laundered

Integration:

Funds get back into circulation as legitimate to purchase goods and services.

AML POLICY

Metropolitan Forex Bureau Ltd providing services on the financial market adheres to the principles of Anti-Money Laundering and actively prevents any actions that aim or facilitate the process of legalizing of illegally gained funds. AML policy means preventing the use of the company’s services by criminals, with the aim of money laundering, terrorist financing or other criminal activity.

For this purpose, a strict policy on the detection, prevention and warning of the corresponding bodies of any suspicious activities was introduced by the company. A complex electronic system for identifying every company’s client and conducting a detailed history of all operations was introduced as well.

To prevent money laundering, Metropolitan Forex Bureau neither accepts nor pays cash under any circumstances. The company reserves the right to suspend any client’s operation, which can be regarded as illegal or, may be related to money laundering in the opinion of the staff.

COMPANY'S PROCEDURES

Metropolitan Forex Bureau will make sure that it is dealing with a real person or legal entity. Metropolitan Forex Bureau also performs all the required measures in accordance with applicable law and regulations, issued by monetary authorities.

The AML policy is being fulfilled within Metropolitan Forex Bureau by means of the following:
KNOW YOUR CUSTOMER AND CUSTOMER DUE DILIGENCE PROCESS

Because of the company’s commitment to the AML and KYC policies, each client of the company has to finish a verification procedure. Before Metropolitan Forex Bureau starts any cooperation with the client, the company ensures that satisfactory evidence is produced or such other measures that will produce satisfactory evidence of the identity of any customer or counterparty are taken. The company as well applies heightened scrutiny to clients, who are residents of other countries, identified by credible sources as countries, having inadequate AML standards or that may represent a high risk for crime and corruption and to beneficial owners who resides in and whose funds are sourced from named countries.

Individual clients

During the process of registration, each client provides personal information, specifically: full name; date of birth; origin; complete address, including phone number and city code. A client sends the following documents of the requirements of KYC and to confirm the indicated information.

Corporate clients

In case the applicant company is listed on a recognized or approved stock exchange or when there is independent evidence to show that the applicant is a wholly owned subsidiary or a subsidiary under the control of such a company, no further steps to verify identity will normally be required. In case the company is unquoted and none of the principal directors or shareholders already has an account with Metropolitan Forex Bureau, the official provides the following documents because of the requirements of KYC:

This procedure is performed to establish the identity of the client and to help Metropolitan Forex Bureau know/understand the clients and their financial dealings to be able to provide the best services in the Industry.

Validating Photo Identification

The photo ID must be issued by a legitimate issuing body. If the customer is not a resident of Uganda, he / she must present his passport. MFB will not accept any form of identification that has expired/not valid.

Acceptable Customer ID’s are:
Monitoring Client Activity

In addition to gathering information from the clients, Metropolitan Forex Bureau continues to monitor the activity of every client to identify and prevent any suspicious transactions. A suspicious transaction is known as a transaction that is inconsistent with the client’s legitimate business or the usual client’s transaction history known from client activity monitoring. Metropolitan Forex Bureau has implemented the system of monitoring the named transactions (both automatic and, if needed, manual) to prevent criminals from using the company’s services. MFB Compliance Officers will always cross check the daily transaction report along with daily receipts for both money remittance & forex on a daily basis.

Forex Transactions

Multiple Forex cash purchases/sale made by one person in one business day must be aggregated, or added together, and treated as a single purchase/sale, even if purchased or sold at different times during the day.

A customer purchase/sale of USD 5,000 and above or equivalent to any other foreign currencies on the same day, company must treat this as a ‘large cash transaction’ and to collect valid photo identification documents (as mentioned above) and source of the funds. All information must be obtained from the customer and documented before processing the transaction both Forex & Money Remittance. Compliance Officer should ensure to file the Large Cash Transaction report to BOU on the next day before 10.00 am of the transaction being processed.

Money Remittance Transactions
Before process any WU/XP/MG send/receive transaction, the concerned staff should ensure:
Maintenance Of Records
Record Keeping

All customer ID’s, supporting documents which include Trading License copy, Invoice details etc. to be filed and keep it in safe place. All record keeping and reporting documentation required by the Bank of Uganda and financial regulatory authority will be maintained for a minimum of ten (10) years and they will be made readily available upon legitimate request.

Consumer Privacy

In accordance with the Privacy Act, the company must protect consumers’ personal and private information. All documents that contain consumer’s private and personal information will be stored in a secure location.

Compliance Officer Job Responsibilities
Employee Training Requirements

Metropolitan Forex Bureau follows a rigid recruitment process, part of it being the mechanism of understanding any relationship of potential employees with any kind of crime/criminal activities.

Within our induction program, which consists of a number of intensive and hands-on training sessions, Metropolitan Forex Bureau trains the newly recruited in the principles, methodologies, policies, and procedures of AML/KYC.

Necessary reading material in the form of Manuals/Book of Instructions relating to various products such as Money Changing/ Money Transfer etc. have been made available to the employees both in soft copy and hard copy form to enable them to read, understand and update their knowledge. Further, the employees shall be given refresher training from time to time so as to update them with the changes in the rules and regulations.

Training is to be provided to all employees (new and existing) on a periodical basis must include: