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AML Policy

KYC/AML/CFT POLICY
YF CORPORATION (herein referred to as “YF CORPORATION”), will maintain and enforce anti-money laundering procedures based on the St. Vincent and the Grenadines “Proceeds of Crime Act, 2013” and the “Prevention of Money Laundering Guidance Notes – 2002 (amended May 19, 2006). Based on the requirements of these Acts, YF CORPORATION is committed to the maintenance of a compliance programme.

Scope and Objectives of KYC/AML/CFT Policy

These procedures are established to guide staff in identifying common practices used in money laundering and terrorism financing, to deter such practices and when discovered or suspected, to use a systematic, uniformed approach for dealing with it.

This Policy will be applicable for all Bank operations, local and international. The objective of this policy is to ensure that the products and services of YF CORPORATION are not used to launder the proceeds of crime and that all of the Bank’s staff is aware of their obligations and the need for vigilance in the fight against money laundering and terrorist financing.

As a policy, YF Corporation is committed to comply with all the regulatory instructions, laws, and regulations (issued from time to time) by the St. Vincent and the Grenadines Financial Services Authority (SVG FSA) and the St. Vincent and the Grenadines Financial Intelligence Unit (SVG FIU) and regulators of the countries where YF CORPORATION operates.

Definitions

- Money Laundering

a) Engaging, directly or indirectly, in a transaction that involves property that is the proceeds of crime, knowing or having reasonable grounds for believing the same to be the proceeds of crime;

b) Receiving, possessing, managing, investing, concealing, disguising, disposing of or bringing into St. Vincent and the Grenadines any property that is the proceeds of crime, knowing or having reasonable grounds for believing the same to be the proceeds of crime;

c) Notwithstanding the above definition (a) and (b) as provided under the Proceeds of Crime Act, a universal definition is “the process whereby the identity of dishonestly and/or illegally obtained money is transformed so that it appears to have originated from a legitimate source”.

- Proceeds of Crime
Any monies derived or obtained, directly or indirectly, through the commission of a prescribed offence (see Appendix A), whether committed in St. Vincent and the Grenadines or elsewhere; and shall include any monies that are knowingly mingled with laundered funds.



- Property
Money, investments, holding, possessions, assets and all other property real or personal, heritable or moveable, including things in action and other intangible or incorporeal property wherever situate (whether in St. Vincent and the Grenadines or elsewhere) and includes any interest in such property.



- Money
Money includes cash, bank cheques, drafts, money orders or traveler’s cheques.



- Identification Record
In the case of a corporate body, the details of the certificate of incorporation, such certificate to be notarized if a foreign company; the most recent annual return and any officer of the company. In the case of a person, sufficient documentary evidence to prove to the financial institution that the person is who that person claims to be.



- Business Transaction
Any arrangement, including opening an account, between two or more persons where the purpose of the arrangement is to facilitate a transaction between the parties concerned and includes any related transaction between any of the parties concerned and other parties.



- Suspicious Business Transaction Report (SBTR)
The Suspicious Business Transaction Report is the document that shall be used for reporting every transaction that is considered to be suspicious that is, unusual or complex which includes but is not limited to large transactions. The SBTR should also be used for those transactions that have no apparent economic or lawful purpose, although the value may be considered insignificant.



- Supervisory Authority
Supervisory Authority means the St. Vincent and the Grenadines Financial Intelligence Unit (SVG FIU) for the time being, and includes any person authorized by the FIU in writing in that behalf.

KNOW YOUR CUSTOMER – Principle and Guidelines

The principle of “Know Your Customer” is critical for any financial institution to monitor unit holders’ activities in order to make a determination as to the existence of money laundering activities.

In this regard, policies and procedures must be established for verifying the identity of all customers (i.e. both new and existing, corporate, unincorporated and individuals). YF CORPORATION shall request from new customers, documentary evidence of identity that includes a photograph (for individuals) and signature/s. Copies of such documents should be retained. Addresses should be verified by for example, a recent valid utility bill and copies of all such documents should be retained on file for a minimum of five (5) years.

YF CORPORATION shall obtain from all customers, including signatories to corporate accounts their full name, date of birth (or Certificate of Incorporation in the case of a Company), nationality, occupation (or the Memorandum and Articles of Association in the case of a Company) and the most recent annual company return filed at the General Registry if necessary.

In the case of a company incorporated outside of St. Vincent and the Grenadines, all forms of identification must be duly notarized. These identification procedures must be followed on the opening of any account and YF CORPORATION should not transact business with any new customer who refuses to provide or provides inadequate evidence of identity. If management suspects that customers are not acting on their own behalf, the true identity of the persons on whose behalf the account is opened or the transaction is conducted, must be verified. Furthermore, in ascertaining details on the origin of the assets and source of income declared by a customer, the staffs at YF CORPORATION are hereby expected to follow the following directions to obtain the information it deems necessary in order to complete an account application for approval or disapproval.

PERSON / ACTUAL OWNER:

Inheritance / Donation
-Indicate from whom the donation was made or who was the testator's request, the relationship with the customer and the activities which generated the patrimony. In the case of entrepreneurial activity also indicate the name of the company if known by the beneficiary.
- Indicate the year in which it was collected.
- Indicate the amount of the inheritance attributable to the customer or the
Entrepreneurial Income
-Indicate the name of the company and attach the all corporate documentation as noted above. which generated the patrimony. In the case of entrepreneurial activity also indicate the name of the company if known by the beneficiary.
- Indicate the net profits of the last 3 years. If the company is at a loss, give useful information about the previous incomes that have generated the wealth. Enter, if available, other financial data such as revenues, number of employees and establishments and the amount of the share capital.
- Indicate the percentage of the client's holdings in the company. - Describe the customer's activity within the company and when it started.
Revenue Employee
-Indicate the name of the company for which the customer has worked / works and which generated the wealth.
- Specify the role within the company.
- Specify if it holds shares of the company and where (Italy or abroad) and their Value/proportion.
- Indicate the average income in the years in which the entrusted assets at YF CORPORATION have been generated and the time period.
- If the revenue has been earned abroad clearly state it in the form indicating the relevant period.
Freelancer/Self-employed
-Indication of any studio / company he works for and which generated the wealth.
- Specify what constitutes his professional activity.
- Indicate the average income in the years in which the entrusted assets at YF CORPORATION have been generated.
Sale of Real Estate / Investments – IPO
-Indicate the year of sale and the location of the property.
- Enter a brief description of the characteristics of the property / indicate the percentage owned.
- Indicate the amount received.
Annuity Financial / Landlord / Housewife / Retired
-Indicate how you generated the initial assets (follow points 1-5).
- Indicate when the assets were transferred to YF CORPORATION and the annual growth rate justifying the current Assets’ value.
- Indicate if there have been significant contributions later (when, how much and from what activity).
- In the case in which the customer refuses to give the required information, the relationship cannot be established.
- Finally, it is important to corroborate information on the assets with documentary evidence or public sources such as: - Inheritance: copy of the inheritance. - Donation: copy of the deed of donation or bank account that certifies the origin of the donor. - Employee income: a copy of a government-issued annual income report (not older than 3 years), or recent pay slip (indicating the monthly salary). - Self-employed: copy of a government-issued annual income report (not older than 3 years). - Sale of property: deed of sale. - Sale of business or investments: evidence from the press or from databases (Cerved, Lynx). In the case of a high money laundering risk profile (ie: 3.Medium, 2.High, 1.Very High according to the YF CORPORATION parameters), the Bank reserves the right to request additional information or evidence without which there is no obligation to establish the relationship with the client or to withdraw from a client relationship after the periodic review of the existing relation.


Type of Customers that YF CORPORATION will not accept
As a policy, YF CORPORATION shall not deal /accept the following types of persons/entities as a customer:
-Gamblers/Bookies.
- UN Registered Money Changers/Exchange Companies.
- Anonymous or Fictitious Accounts.
- Shell banks/ Companies.
- Unregistered Arms-related business.
- Accounts where the customer is acting on behalf of another customer to open an account. (The account shall be opened in the name of the person who is the beneficial owner of the funds in the account).
- Entities/Persons appearing in Negative/Sanctioned list. Proscribed entities and persons or to those who are known for their association with such entities and persons, whether under the proscribed name or with a different name. - Entities/Persons appearing in OFAC/EU & UN lists and any other list recommended by the SVG FSA and/or SVG FIU.

Sanctions Lists that YF CORPORATION will use:
1. UN Sanctions list: http://www.un.org/sc/committees/list_compend.shtml
2. Office of Foreign Assets Control Specially Designated Nationals and Blocked Persons List http://www.treasury.gov/resource-center/sanctions/SDNList/Pages/default.aspx
3. EU-List http://ec.europa.eu/external_relations/cfsp/sanctions/list/version4/global/ global.xml http://eeas.europa.eu/cfsp/sanctions/consol-list_en.htm
4. Sanction lists issued by the SVG FSA and SVG FIU.
5. YF CORPORATION’s Internal List to be developed

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