1. Purpose
Appra is committed to the highest standards of Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) compliance. This policy outlines our framework for detecting, preventing, and reporting suspicious activity.
2. Customer Due Diligence (CDD)
We perform thorough identity verification on all customers, including:
• Government-issued ID verification
• Proof of address documentation
• Source of funds verification for higher-risk transactions
• Enhanced due diligence for politically exposed persons (PEPs)
3. Transaction Monitoring
We employ real-time transaction monitoring systems that flag unusual patterns, including:
• Transactions exceeding defined thresholds
• Rapid movement of funds across multiple accounts
• Transactions involving high-risk jurisdictions
• Structuring or layering patterns
4. Suspicious Activity Reporting
When suspicious activity is detected, we file reports with the relevant Financial Intelligence Units (FIUs) in applicable jurisdictions. Staff are trained to identify and escalate suspicious transactions.
5. Sanctions Screening
All customers and transactions are screened against international sanctions lists, including UN, EU, OFAC, and HMT lists. Matches result in immediate freezing and reporting.
6. Record Keeping
We maintain comprehensive transaction records and customer identification data for a minimum of 5 years, or longer where required by local regulations.
7. Staff Training
All employees receive regular AML/CTF training. Compliance officers receive specialized training and certifications to stay current with evolving regulations.
8. Contact
For AML-related inquiries, contact our compliance team at compliance@appraglobal.com.