Send2Family is committed to prevent money laundering and terrorist financing in accordance with the Financial Conduct Authority (FCA) regulations, Financial Action Task Force (FATF) requirements and international best practices in Anti-Money Laundering (AML) & Counter Terrorist Financing (CTF). As a result, we are prepared to identify suspicious activities related to money laundering, fraud, financing of terrorism, and financing of illegal groups and report them in accordance with the law to the National Crime Agency (NCA). Send2Family is committed to operating legally and ethically and in accordance with all relevant laws and regulations. We have therefore implemented a robust AML and compliance system in all our branches. Our up to date information technology infrastructure and AML solutions enable us to be fully compliant at all times.

Anti-Money Laundering Compliance Policy Declarations

Send2Family is fully committed to adhering to the laws and regulations which reflect the relevant recommendations issued by the Financial Action Task Force (FATF) and the Basel Statement of Principles on preventing the utilization of the banking system for criminal purposes, issued by the Basel Committee.Send2Family is also determined to constantly evaluate and uphold its AML policies, procedures and controls on an on-going basis by ensuring befitting internal and external audit program.

Send2Family adheres to the following robust AML / Compliance program:

• Risk Assessment
• Policies and Procedures
• Governance and The Compliance Officer
• Customer Due Diligence
• Transaction Monitoring
• Sanctions Obligations and freezing without delay
• Training 
• Independent Audit
• Record Keeping Managing Employee Risk

Know Your Customer (KYC)

We follow a strong identity verification process for all our customers as per local and international AML/CTF regulations irrespective of the amount of the transaction.

Robust KYC (Know Your Customer) and KYCC (Know your Customer’s Customer) policies are adhered to at all levels of the organization. Identifying and conducting Simplified Due Diligence (SDD), Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) wherever required is a normal process at Send2Family for identifying the customer, wealth source and purpose of transaction.

Simplified Due Diligence (SDD)

Simplified Due Diligence is only performed on Low risk customers where the minimal documents are obtained to execute the transactions.

Customer Due Diligence (CDD)

In our CDD process, we obtain relevant details of every customer to ensure that the transactions they perform are in line with their profile or business activities. Our focus has always been to ensure the legitimacy of the source of funds and purpose of transaction. 

Enhance Due Diligence (EDD)

EDD is to perform additional measures, besides the usual CDD, to know more about the customer, his source of funds and to confirm that the transactions are within its means. To verify that funds are legitimate and not related to any criminal proceeds by obtaining authentic and genuine documents which must support both the underlying and stated purpose? Send2Family adopts a risk-based approach to identify and eliminate potential risks. Hence EDD is compulsorily performed on all high-risk accounts. For all Remittances and FC buying & selling above GBP 5,000 the EDD is performed.

Risk Assessment

We at Send2Family perform both Enterprise Wide Risk Assessment (EWRA) and Customer risk assessment at three different levels like On-boarding, transaction and profile. This risk assessment helps us to identify the customers as per their risk profiling and we become more vigilant and pro-active.

Sanctions Screening

To ensure compliance with the applicable sanctions against persons and entities, Send2Family has an automated system (World Check) to screen the names of the customers against the sanctions lists issued by the Her Majesty Revenue & Customers (HMRC), the UN Security Council (UNSC), The Office of Foreign Assets Control (OFAC), The Office of Financial Sanctions Implementation (OFSI) the list issued by European Union (EU). Along with the customers’ names, all the parties to the transactions are also filtered through the screening system in order to ensure compliance with Sanctions Obligations.

Transaction Monitoring

Send2Family ensures that an ongoing ‘Transaction Monitoring’ is conducted to detect transactions which are unusual or potentially suspicious based on the customer profile/ behavior. The front end staff acts as a first line of defense and is empowered to escalate any unusual behavior/ transactions through internal channels. This process is supplemented by an extensive review of the transactions at the second line of defense including increased monitoring of the customer’s transactions and behavior.

Reporting of Unusual or Suspicious Transactions

All our staff are trained and equipped to report unusual or potentially suspicious transactions through our internal channels to the compliance officer. The compliance officer, conducts an in-depth investigation and takes appropriate action before reporting such transactions to the National Crime Agency (NCA).

Staff Training

We also perform KYE on all our staff before on-boarding them which mainly includes Police Verification, Screening and Previous Employer reference check etc.

Record Keeping & Confidentiality

All records including the customer’s identification documents, related data, transaction data and any other relevant document are maintained and retained for a minimum of five years. This is in line with the regulations of the Financial Conduct Authority (FCA). Send2family shall always maintain the confidentiality of information provided by its customers and their transaction records.

Independent Review of the Compliance & AML Department

Compliance & AML function is subject to reviews by Internal Audit, the FCA examiners as well as independent external auditors. This ensures that the compliance program is always up-to-date and is meeting all the regulatory requirements.

Know Your Employee

We also perform KYE on all our staff before on-boarding them which mainly includes Police Verification, Screening and Previous Employer reference check etc.