AML (Anti-Money Laundering) Policy and KYC (Know Your Client) Policies
1. The anti-money laundering (AML) and counter terrorism funding policy of the “EXCO” (RSG Finance Ltd.), collectively referred to herein as “the company”, “our”, “us”, “we” or “EXCO”) is aimed at fulfilling the requirements of the rules and regulations that are internationally acceptable. The purpose is to ensure that our business is not used to facilitate money laundering and to comply with all applicable laws. The Company has zero-tolerance policy for money laundering activities.
2. The Company takes AML very seriously and any deviance from our practices will result in immediate action. The Company reserve the right to refund, deny or withhold any deposit made against this policy, or is suspected according to the applicable law, to be AML related (such as transfer to or from a suspected jurisdiction etc.).
KYC - identification and verification of new customers, deposits, transfers and withdrawals
1. In order to open up an account with The Company, the client must submit the following:
- First Name,
- National I/D or Passport Number,
2. The client must also send a copy of his/hers National I/D. The National I/D should contain the following (all or some, according to the Company's discretion:
- A photo of the holder,
- the national I/D number,
- the holders full name,
- the holder's father's first name,
- the holders mother's first name,
- the holders nationality and place of birth,
- the holder's date of birth,
- the holder's place of birth,
- the holder's sex,
- the holder's address,
- the holders marital status,
- the holder's spouses details such as their National I/D number.
3. Further details and checks are performed upon a Customer depositing Funds. All accounts opened must be in the same name as the funder of the account. The Company will accept no third party funding.
4. Verification against Credit Card slips or details supplied by The Company's Credit Card handlers and/or verification against bank transfers from clients after a transfer and/or verification against actual cheques will be crosschecked against details already supplied by the customer. Only upon verification will the account be opened. Any discrepancy will not be tolerated and funds will be returned to sender in the same way that they were sent.
5. Credit Card deposits will be subject to our credit card clearing Company's fraud and anti-money laundering procedures.
6. All client withdrawals will be only be permitted to exactly the same account and exactly the same name from which original customer funds were received. There will be no third party transfers.
7. The funds will also be transferred in exactly the same way of the original funding of the account. For instance withdrawals requested by a customer that transferred his original deposit via Credit Card will receive hi funds as a refund from his credit card, up to the maximum of his deposit.
8. Repeat credit card depositors or client depositing over $5,000 in total deposits will require further inspections.
9. Withdrawals will only take place after written and signed requests and copies identifying the bank account as the clients and corresponding to previously received documentation.
10. The Company will at its own discretion ask for further proof of identification should for any reason the Company employee's suspicions arise.
11. Suspicious activity such as the method of deposit, suspicious circumstances such number of transfers will be monitored.
12. Verification will be performed at the account opening or within a reasonable time after opening of the account. The methods will include document and non-document methods.
13. In circumstances where The Company cannot form a reasonable belief on the customer's identity the account will not be opened. The Company customer account system does not allow for account opening unless verification has been done as per company policy.
14. Records will be maintained for 5 years of all identifying documents obtained from a customer – either a copy or a description of the document used to verify identification. Also to be kept will be any document which resolves any discrepancy discovered recording the identity.
Detecting and reporting suspicious activity
15. Regarding high risk accounts appropriate extra due diligence procedures will be taken i.e. further documents, phone calls or meeting face to face with clients, bank references and certification of certain documents.
16. When deemed necessary we will perform additional monitoring of specific account activities.
17. We maintain systems and procedures to detect and require reporting of suspicious activity.