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One IBC® Safeguard is designed to allow us to better protect you, support you and your accounts from fraud and financial crime. To do this we need to ensure that all the information we hold for you or your business is correct, complete and up-to-date. Changes in regulations may also mean that we require some additional information which we have not previously asked you to provide.
If you're a personal customer we're likely to need 2 types of documents from you: to confirm your identity, and to confirm your address. Occasionally we may need more information than this.
If you're a business customer the documents we need will depend on the size and nature of your business. However we are likely to need to confirm your legal entity structure, your beneficial owners and countries you do business with.
The sole purpose of gathering this information is so that our systems and processes can protect both our customers and the One IBC® against financial crime. We take our obligation to protect your data very seriously, so all the information you provide will be subject the One IBC®'s high data and security standards. The intent is only to use this information for your protection and will NOT be used by any third parties for marketing purposes.
Fraud and financial crimes are forms of theft. They tend to involve money or property that are gained illegally, and used in a deceptive or illegal manner to gain a benefit from the proceeds. In today's complex economy, financial crimes can take many forms including money laundering, sanctions breaches, fraud, tax evasion, terrorist financing, bribery and corruption.
Financial crime can affect anyone and everyone. Your support will go a long way to help us do business safer.
Sanctions are a policy tool which national governments and organisations such as the United Nations and European Union use to constrain and deter perceived threats to their security, or to conform international conduct to recognised international standards. Sanctions help to stop crimes like terrorism, drug trafficking and arms dealing by imposing restrictions on the business that banks can do with specific people, corporations or countries and the names of these are clearly listed on things like the Office of Foreign Assets (OFAC) sanctions list.
At One IBC®, addressing financial crime globally has long been one of our main priorities.
However criminal activity has become increasingly sophisticated in recent years, and fraudsters, money launderers and others have attempted to target global networks.
Improving the way we share and manage customer information will help us fight against the risk of financial crime. After all, it's our duty to ensure that you can do business with us safely, securely, and confidently.
As the world becomes more and more connected and information moves around at a greater pace, there are unfortunately greater opportunities for criminals to misuse the financial system.
A key defence against money laundering is to prevent accounts being opened in false identities. We also sometimes need to verify where funds are from as part of our ongoing efforts to track our customers' legitimate funds and to protect them from financial crime. Criminals will try to appear to be law abiding citizens or businesses and therefore we need to request documentary evidence from all of our customers in order to fully protect them and their accounts.
As well as acting to safeguard our customers, One IBC® has a commitment to meet regulatory and legal requirements by ensuring that the information we hold is up-to-date, complete and accurate. You might have already provided some of this information prior to this request, but to stay one step ahead of fraud and financial crime, we need to ensure we have your most up-to-date information.
The request you receive from us will detail all the information required, in most cases this will include a certified copy or original document verifying your residential address. For some of our customers we may also require a certified copy of your identification documentation (e.g. a valid passport). We'll advise exactly what you'll need to provide when we contact you. In certain cases we can only accept original documents which must be sent to us by post.
Regulatory and legal obligations require us to understand where funds are coming from and going to. This also helps us to protect you from fraud and financial crime.
We are required by our regulators to have this information. If we don't receive your up-to-date information we may no longer be able to provide you with our services. If you are having trouble gathering the information, need more time or have any further questions, please let us know and we will do our best to help.
Documents and Certification
The following people can certify photocopies of your documents, on sight of the original document:
*Who is a member of a recognised professional body
If you provide original utility bills to confirm your address, these do not need to be certified. We regret that we will not be able to return these documents to you.
Your documents must be certified within the last three months and be in English. We can only accept certified copies that have been translated into English, providing both the foreign and English copies are certified as required.
Once your documents are certified, please send them with your completed Personal Information Form to the following address: Unit 1411, 14/Floor, Cosco Tower, 183 Queen's Road Central, Sheung Wan, Hong Kong and/or scan it then send over email to [email protected].
The One IBC® approach to conduct is designed to ensure that through our actions and behaviours we deliver fair outcomes for our customers and do not disrupt the orderly and transparent operation of our business. Conduct is the critical component within all business activities including, including but not limited to strategy, business models and planning, our culture and behaviours including staff recruitment/performance management, our interaction with customers, our products and services, our business operations, and our governance and oversight processes.
Our approach to conduct is key to winning and retaining our customers’ trust and loyalty. Focus on conduct is integral to One IBC®’s values and business principles and supports the Group strategy for sustainable growth and streamlining of business processes and procedures.
One IBC® has defined global outcomes relating to conduct which must be delivered by global businesses, global functions, and Operations, Services and Technology, each responsible for conduct within the scope of their activities, and must develop and maintain approaches, tailored to their markets and operations, which deliver the required global conduct outcomes.
Activity and decision making within each global business, global function, and One IBC® Operations, Services and Technology is expected to provide positive contribution to the global conduct outcomes, to ensure appropriate delivery of these outcomes.
Our commitment to the highest standards of conduct and their embedding within our day to day activities is illustrated for example by our policy relating to complaints handling, which supports outcome:
Our global complaints policy sets out clear standards for:
This conduct commitment is further illustrated by our policy and procedures in respect of product governance and sales which support the customer pillar outcomes, and encompass standards for:
Our Charter makes clear that if our staff have concerns that the standards contained in our policies and procedures, or any other aspects of our conduct are not being adhered to, they can speak up – for example:
Provide one of the documents below and make sure it's both current and a certified copy (not the original).
Provide one of the documents below and make sure it's both recent and certified.
Ask one of the possible certifiers below to write the relevant statement on each of the documents they verify, if any of the documents are more than one page long ask the certifier to write the statement on the first page and sign any subsequent page.
We can only accept the following certifiers, they must be registered and active; financial institutions, lawyers, solicitors and notaries.
Next, ask your chosen certifier to write this on the document they are certifying:
I (full name of certifier) confirm that this is an accurate copy of the original and the photo is a true reflection of the applicant.
I (full name of certifier) confirm that this is a true copy of the original document for (full name of customer).
It is important each document contains this information as without it we may not be able to accept them. The person signing the document must be active in the profession and can't be a relative, friend or someone who lives at your address. We may contact them for verification.
The same document cannot be used twice to verify identify and address, so a different document must be used to meet the regulations and the One IBC® criteria.
First version date: 01 April 2018. Latest update: 03 September 2018
ONE IBC® is Private Limited company, a Company Services Provider (non-financial services) support to client worldwide to incorporation company, maintain and compliance with Hong Kong Company Registry as well as other related authority. ONE IBC® committed to the highest standards in effort to comply with the applicable Anti Money Laundering and Counter Financing Terrorism (AML-CFT) standards. The Policy provides an introduction to anti money laundering and counter financing terrorism regulation.
The Management (BOD) and all employees are required to adhere the standards to protect ONE IBC® and its reputation from being misused for money laundering and/or terrorist financing or other illegal purposes.
Government has enacted laws and rules designed to implement the anti-money laundering and counter financing terrorism. The goal of these laws is to detect and prevent money laundering and potential terrorist financing. ONE IBC® will adhere to applicable laws and regulations in Singapore.
ONE IBC® will verify its AML – CFT framework, goals and strategies on an periodical basis and maintain an effective program for the ONE IBC®’s business that reflects the best practices for financial institution in general.
ONE IBC® has active Supervisory Board under Compliance Officer, and the implementation of AML – CFT Program handled by AML – CFT Officer and all the team members (“MLRO”) which has been appointed by the Management. The MLRO is responsible for adherence to applicable AML – CFT Program derived from AML-CTF procedure.
ONE IBC® has created a set of policy and procedures concerning general AML standards and principles. The governance ensures that the standards are implemented into day-to-day operational activities. All policy and procedures are published on accessible media so it can be accessed by all employees. They are subject to periodical review to ensure their conformity with recent and updated AML – CFT regulations.
The scope of this policy covers all aspects of the Implementation of Anti Money Laundering and Counter-Financing Terrorism Prevention Program, namely:
ONE IBC® has implemented know your customer (KYC) procedure to assure all kinds of customers are subject to identification and verification process. The KYC has been implemented in all branches and business units. The goals are ONE IBC® has sufficient information and data about the customers profile, whom they deals with, and also the Ultimate Beneficial Owners (UBOs). The procedures include mandatory documents requirements, enhanced due diligence for politically exposed persons (PEPs) and customers from high risk businessess or countries, name screening, and the ongoing monitoring and updating data of all existing customers.
ONE IBC® shall refuse to support or has to close an existing clients, if the following:
ONE IBC® has an obligation to report cash transaction with certain amount based on relevant regulation, suspicious transaction/activity, and international fund transfer. Suspicious transactions must be handled and escalated with approval of Compliance Officer prior reporting to regulator.
The AML-CFT Entity Risk Assessment is prepared by conducting inherent risk assessment activities, establishing risk tolerance, formulating mitigation and risk control measures, residual risk evaluation, applying a risk-based approach, and reviewing and evaluating approaches based on risk. AML-CFT MLRO identifies, assesses, and understands the risks of money laundering and or criminal acts of Terrorism Financing based on customer, country or geographical factors, products, services, transactions or distribution channels (delivery channels).
Sanctions Compliance Implementation is important in ONE IBC® activities. ONE IBC® obligates to establish restrictions and controls on the movement of goods, services, and customers' funds were transacted through the products and services that provided by ONE IBC®. Sanctions Compliance implementation goal is to keep ONE IBC® from compliance risk, operational risk and reputational risk exposure. ONE IBC® implements AML-CFT Sanctions procedure as a form of risk mitigation and guidance to relevant working units. The implementation based on ONE IBC® and Sanctions regulations issued by the government/local jurisdictions, international institutions / multilateral and clearing countries.
ONE IBC® has to record all data and or information regarding customers documents, client’s companies and/or its financial transactions (if any). ONE IBC® maintains customers documentations for minimum of 5 (five) years, notwithstanding to longer retention as required. ONE IBC® will provide information and/or documents competent authorities as ordered by laws and regulations, when required.
ONE IBC® has implemented AML – CFT training program for all staff. ONE IBC®’s training program is tailored to the operations and business unit to assure all staffs are aware of different patterns, methods, techniques, and typologies of money laundering or terrorist financing which may occur in daily operational activities. The training programs cover policy and procedures for the implementation of AML – CFT Program as well as roles and responsibilities of employees to assist in the eradication of money laundering or terrorist financing.
ONE IBC® has an effective internal control system. ONE IBC®’s AML – CFT Program is subject to independent control by Internal Audit function. The control demonstrates the adequacy of policy, procedures, internal monitoring, and responsibilities of working units associated with the implementation of AML – CFT Program.
This Policy is an integral part of ONE IBC®’s Anti-Money Laundering and Counter Financing Terrorism Procedure and shall take effect from 01 April, 2018.
Vu Dai Duong
Risk & Compliance Manager.