Introduction

At CFG-Holdings Plc, we are committed to implementing robust measures to combat money laundering (AML) and the financing of terrorism (CTF). Our compliance framework is designed to protect the integrity of our financial systems, ensure compliance with applicable laws and regulations, and safeguard our reputation in the market.

1. AML/CTF Governance Structure
   1.1 Establishment of an AML/CTF Compliance Program
   • CFG-Holdings will develop and maintain a comprehensive AML/CTF compliance program that adheres to relevant laws and international best practices.
   • This program will include policies, procedures, and controls to detect, prevent, and report suspicious activities.

1.2 Designated Compliance Officer
• We will appoint a designated AML/CTF Compliance Officer responsible for overseeing the implementation and effectiveness of our AML/CTF program.
• The Compliance Officer will report directly to the board and ensure that all staff are aware of their roles in maintaining compliance.

2. Risk Assessment
   2.1 Conducting Regular Risk Assessments
   • CFG-Holdings will perform regular risk assessments to identify, assess, and understand the money laundering and terrorist financing risks associated with our products, services, customers, and geographic locations.
   • The results of these assessments will inform our AML/CTF policies and procedures.

2.2 Customer Risk Profiling
• We will establish a risk-based approach to customer due diligence (CDD), including the development of risk profiles for each customer based on factors such as their business activities, geographic location, and transaction patterns.
• High-risk customers will be subject to enhanced due diligence (EDD) measures.

3. Customer Due Diligence (CDD)
   3.1 Know Your Customer (KYC) Procedures
   • CFG-Holdings will implement robust KYC procedures to verify the identity of our customers and understand the nature of their business.
   • This will involve obtaining relevant identification documents, verifying customer information, and conducting ongoing monitoring of customer transactions.

3.2 Ongoing Monitoring
• We will conduct ongoing monitoring of customer transactions to detect unusual or suspicious activities that may indicate money laundering or terrorist financing.
• Any suspicious transactions will be investigated and reported to the relevant authorities in accordance with applicable regulations.

4. Training and Awareness
   4.1 Employee Training Programs
   • CFG-Holdings will provide regular training and awareness programs for employees regarding AML/CTF regulations, internal policies, and procedures.
   • Training will cover the identification of suspicious activities, reporting obligations, and the importance of compliance in protecting the organization.

4.2 Compliance Culture
• We are committed to fostering a culture of compliance within the organization, emphasizing the importance of adhering to AML/CTF regulations and ethical conduct in all business activities.
• All employees will be encouraged to report any concerns or suspicions regarding potential AML/CTF violations.

5. Reporting Obligations
   5.1 Suspicious Activity Reporting (SAR)
   • CFG-Holdings will establish procedures for reporting suspicious activities to the relevant authorities, including the Financial Intelligence Unit (FIU).
   • We will ensure that all SARs are submitted promptly and include all necessary details regarding the suspicious activity.

5.2 Record Keeping
• We will maintain comprehensive records of all customer due diligence, transaction monitoring, and suspicious activity reporting for a minimum period as required by law.
• These records will be readily available for inspection by regulatory authorities.

6. Compliance Audits and Reviews
   6.1 Regular Audits of AML/CTF Program
   • CFG-Holdings will conduct regular internal audits and reviews of our AML/CTF compliance program to assess its effectiveness and identify areas for improvement.
   • External audits may also be conducted to ensure objectivity and adherence to regulatory requirements.

6.2 Continuous Improvement
• We will continuously improve our AML/CTF policies and procedures based on audit findings, regulatory changes, and emerging risks in the financial landscape.
• Feedback from employees and stakeholders will be solicited to enhance our compliance efforts.

Conclusion
CFG-Holdings Plc is dedicated to implementing effective measures to combat money laundering and the financing of terrorism. Through a robust AML/CTF compliance framework, we aim to uphold the highest standards of integrity and transparency, ensuring the trust of our stakeholders and the broader community.