UNI FIN INVEST AML / CTF policy

1. Policy statement

UNI Fin Invest (the Company) is incorporated under the legislation of the Republic of Mauritius, with its registration address at Office 306, 3rd Floor, Ebene Junction, Rue de la Democratie, Ebene, Republic of Mauritius and holds Investment Dealer Full-Service Dealer, excluding Underwriting license issued by the Financial Services Commission (FSC).

UNI Fin Invest is regulated in Mauritius and complies with the Financial Intelligence and Anti-Money Laundering Act (FIAMLA) and guidelines set forth by the FSC to prevent money laundering and terrorism financing.

In line with these regulations and its internal policies, UNI Fin Invest is obliged to perform due diligence on clients. This includes verifying client identity, analysing transactions, identifying beneficial owners, assessing sources of funds, and monitoring and reporting any suspicious transactions.

By accepting the Company’s Customer Agreement on our website, Customers acknowledge and understand that UNI Fin Invest may conduct these due diligence processes as necessary without the need for prior notice or additional consent. In case of complex due diligence processes or investigations, the customer account activity may be limited.

2. Scope of this AML/CTF policy

This policy applies to all UNI Fin Invest officers, employees, clients and products and services offered by UNI Fin Invest. All business units within UNI Fin Invest will cooperate to create a cohesive effort in the fight against money laundering. UNI Fin Invest has implemented risk-based procedures reasonably expected to detect, prevent, and report transactions, if applicable. All efforts exerted will be documented and retained.

3. Definition of money laundering and terrorism financing

Money laundering is the process of disguising the origins of illegally obtained money, typically by passing it through a complex sequence of banking transfers or commercial transactions to make it appear as legitimate income. It generally involves three stages:

  1. Placement: Disposal of illicit funds, often through deposits into bank accounts, to introduce them into the financial system.
  2. Layering: Moving funds through a series of transactions to disguise their origin, making it difficult to trace them back to criminal activity.
  3. Integration: Reintroducing 'cleaned' funds into the economy, allowing criminals to use them without suspicion.

Money laundering includes various activities designed to disguise the origin of funds derived from criminal acts. These activities may involve:

  • Acquiring, using, or possessing criminal property: Holding or using property obtained from criminal activities.
  • Handling proceeds of crimes: Moving funds from crimes such as theft, fraud, or tax evasion.
  • Involvement with criminal or terrorist property: Engaging knowingly with funds tied to criminal or terrorist activities.
  • Facilitating laundering arrangements: Participating in arrangements that enable the laundering of criminal or terrorist property.
  • Investing criminal proceeds in financial products: Embedding illicit funds into financial products.
  • Investing in property/assets: Using criminal proceeds to acquire real estate or other tangible assets.
  • Transferring criminal property: Moving criminal property within or across jurisdictions to evade detection.

Money laundering does not always follow a linear process—it can involve straightforward transactions, such as the purchase of luxury items (e.g., cars or jewellery), or complex webs of legitimate business operations designed to conceal the true source of funds. While cash may be the initial form, criminal property can also include rights, real estate, or other benefits. Knowing or suspecting that property is derived from criminal activity without reporting it constitutes participation in the laundering process.

Financial institutions and related businesses must recognise that no sector is immune to criminal activity. Therefore, businesses should assess the money laundering risks associated with their products and services and maintain robust AML controls to mitigate these risks.

Terrorist financing is the process of legitimate businesses and individuals that may choose to provide funding to resource terrorist activities or organisations for ideological, political, or other reasons. The Company must ensure that:

  1. Clients are not terrorists or terrorist organisations themselves
  2. And they are not providing the means through which terrorist organisations are being funded.

Terrorist financing may not involve the proceeds of criminal conduct but rather an attempt to conceal the origin or intended use of the funds, which will later be used for criminal purposes.

4. Risk-based approach

A risk-based approach to AML procedures ensures that the level of due diligence is proportionate to the risk associated with each relationship. This method allows for increased scrutiny where the potential for money laundering is higher, focusing efforts where they are most needed.

Key risk factors are assessed as follows:

  1. Client risk

    Different client profiles carry different risk levels. A basic Know Your Client (KYC) check helps to determine the risk posed by each client.

  2. Product risk

    The risk associated with certain products or services depends on their potential as tools for money laundering. Products with characteristics that may facilitate illicit activities are considered higher risk, requiring heightened due diligence and monitoring.

  3. Channel risk

    The way the Company accepts customers and delivers its products and services affects its vulnerability to ML/TF. When identifying the risk associated with delivery channels, the Company considers the risk factors related to non-face-to-face business relationships. The Company ensures that the documents received are adequately verified and that the customer’s identity is confirmed to ensure the authenticity of these documents.

  4. Country risk

    The geographic location of the client or origin of business activity is a risk factor, as countries vary in their AML/CTF regulatory frameworks. Jurisdictions with weaker AML/CTF controls may present a higher risk of money laundering. Increased due diligence is therefore applied to clients or transactions linked to countries with elevated AML/CTF risks.

By evaluating these risk factors, resources can be allocated efficiently, focusing on high-risk areas, enhancing due diligence, and ensuring effective compliance with AML requirements.

5. Customer Due Diligence

A. Customer Due Diligence (CDD) involves identifying and verifying clients to assess their risk level and ensure compliance with AML/CTF regulations. UNI Fin Invest conducts CDD on all clients.

The following information is required for customer verification purposes:

  • Full name, date of birth, nationality, and residential address.

The following documents are required for customer verification purposes:

  • National ID card, passport, or other government-issued identification documents.
  • Utility bills, bank statements, or other address confirmation documents

(An address confirmation document must be dated within the last three months).

For KYC purposes, information such as contact data, activity, volumes, and the source of funds is required.

Information, such as tax identification number and country of tax residence, is required for common reporting standard purposes.

B. Enhanced Due Diligence measures are applied to higher-risk business relationships to mitigate the risk of money laundering or terrorist financing. These measures may include, but are not limited to:

  1. Collecting additional information on customer profiles and the nature of the business relationship.
  2. Collecting and verifying additional information on the source of funds or source of wealth.

The following activity could trigger the application of EDD:

  • Politically Exposed Persons (PEPs)
  • Customers with adverse media reports
  • Customers whose business activities present a higher risk of money laundering or terrorist financing
  • Other factors

C. Ongoing monitoring:

In accordance with FIAML Regulations 2018, Company conducts ongoing monitoring of a business relationship, which includes scrutiny of transactions undertaken throughout the course of the relationship, including, where necessary, the source of funds confirmation, to ensure that the transactions are consistent with its knowledge of the customer.

D. Identification of Politically Exposed Persons (PEPs):

  • A PEP is an individual who holds a prominent public position (e.g. Heads of State or government, senior politicians, senior government, judicial or military officials, senior executives of state-owned corporations, important political party officials, etc.) or has close ties to such individuals.
  • Additional measures, such as enhanced due diligence, are applied for PEPs due to their higher risk for potential corruption or influence-related risks.

E. Record-keeping:

  • All identification documents, transaction records, and risk assessment documentation are retained for at least seven years after the end of the business relationship with the customer.

6. Suspicious transaction reporting

Suspicious activity, or 'red flags', indicates potential money laundering or other illicit activities. These include unusual transaction patterns, behaviour inconsistent with a customer's profile, or connections to high-risk jurisdictions. When suspicious activity is identified, further due diligence is required. If no reasonable explanation is found, the activity must be reported to the AML department.

Examples of red flags:

  • Reluctance to provide or unusual concern about compliance, business details, or identification.
  • Transactions lack business rationale or are inconsistent with the client’s stated strategy.
  • False or misleading information regarding the source of funds or assets.
  • Unexplained or extensive account activity, especially in previously inactive accounts.
  • Transactions involving high-risk jurisdictions or third parties with no legitimate connection.
  • Requests to bypass normal documentation or transaction processes.

Reporting suspicion

Any suspicious activity must be reported as soon as practicably possible. Internal reports must be made regardless of whether any business was, or is intended. If necessary, a suspicious activity report could be submitted to the regulatory authorities.

Freezing of accounts

Accounts linked to criminal activity or fraudulent transactions may be frozen. This applies if the account holder is suspected of involvement in such activities.

7. Sanctions and terrorist / proliferation financing

As a financial institution licensed in Mauritius, the Company complies with the United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019, which enables the implementation of UN Security Council measures aimed at international peace and security, including countering terrorism, terrorist financing, and the proliferation of weapons of mass destruction.

Sanctions may include financial restrictions, arms embargoes, travel bans to support conflict resolution, nuclear non-proliferation, and anti-terrorism efforts.