POLICY STATEMENT

Keystones Partners Ltd (commercial name “Fitrade Partners”) take a zero-tolerance approach to being involved in illegal/illicit activity, and will fully comply with all relevant sections of UK’s AML/CFT regulatory and supervisory regime, under the Sanctions and Anti-Money Laundering Act

2018 (SAMLA).

All partners and employees of the firm are under an obligation and duty to comply with the above. This policy & any related procedures aims to help partners and staff fulfil these responsibilities, by providing a clear framework, along with setting out the firm’s key principles and obligations.

1. Failure to fulfil these responsibilities may result in disciplinary action and may also result in criminal sanctions for the staff involved.
2. Furthermore, a report may also have to be made to law enforcement agencies, which may result in a criminal investigation.

Key responsibilities of staff therefore include (but are not limited to):

1. Conducting an adequate risk assessment and appropriate due diligence (CDD) on corporate clients, including adverse media, PEP and sanctions checking, before onboarding and any transaction being made.
2. Monitoring all clients/transactions on an ongoing basis for potential money laundering or terrorist financing activity.
3. Reporting any suspicious activity in respect of client or transactions to the
4. Avoiding discussing any potential or actual suspicious activity report with clients or any third parties (“Tipping off”)
5. Undertaking any AML-related training provided by the Firm.
6. Keeping appropriate records of all AML related activity

ENTITY RISK PROFILE SECTION

The partners believe Keystones Partners Ltd is at a low risk of being used to launder the proceeds of crime. This is based on the following factors:

1. Failure to fulfil these responsibilities may result in disciplinary action and may also result in criminal sanctions for the staff involved.
2. Low turnover of clients and a stable existing client base
3. Only dealing with vetted corporate clients
4. Low proportion of one-off clients/deals
5. Mostly front to front contact with clients
6. staff presence in the geographical environment where we operate.
7. Transactions only done via bank transfer.

RISK BASED ASSESSMENT SECTION:

Keystones Partners’s approach/procedures to risk assessment:

1. Back-office is responsible for undertaking the due diligence and initial risk assessment.
2. The partners and the Director are responsible for approving risk assessment.
3. No transaction is done with a client before successfully completing completion of the onboarding process.
4. The client’s file is reviewed once a year.
5. All non-UK/EU clients are considered high risks. Therefore, a thorough due diligence is undertaken before any transaction to ensure the genuine nature of the business and the source of income.

CUSTOMER DUE DILIGENCE PROCEDURES SECTION

Here, detail firm’s procedures in relation to taking ID & Verification, KYC, Source of Wealth (SoW) checks, ongoing monitoring:

1. Our back-office is responsible for taking ID document and verification. This is done face to face, in the company’s office.
2. ID document and verification is required from the owner/managing director of our corporate client.
3. Acceptable ID Documents: Passport/ ID card

Politically exposed persons (PEPs):
The firm will not accept entering in transaction with company managed or controlled by a PEP.

International Sanctions Checking:

The firm will conduct a sanctions list check on each new client/supplier via the HM Treasury website (or an electronic verification system if used) to check if the client or source of funds is related to a sanctioned jurisdiction/regime, and conduct ongoing checks periodically (at least annually for all clients)

1. https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets

Adverse media check:

Google search:
“Counterparty legal name” AND launder OR fraud OR bribe OR corrupt OR arrest OR blackmail OR breach OR convict OR court case OR embez OR extort OR felon OR fined OR guilt OR illegal OR impris OR jail OR kickback OR litigat OR mafi OR murder OR prosecut OR terroris OR theft OR unlawful OR verdict.

ONBOARDING CHECK LIST

AML for FITRADE PARTNERS INTERNATIONAL LTD.pdf

FURTHER INFORMATION

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1085407/MLRs_Review_Report_-_2.5_for_publication.pdf