Anti-Money Laundering Policy
ZellaTrade (“the Company”) aims to prevent, detect and not knowingly facilitate money laundering and terrorism financing activities. The Company does this to protect its reputation, to comply with relevant laws and requirements, as well as to be a good corporate citizen. The Company also aims to comply with anti-money laundering (“AML”) and counter-terrorism financing (“CTF”) recommendations in a way that complements business priorities.
The management of the Company places extremely high importance on assisting in discovering any money laundering scheme.
These policies are to be read by and adhered to by all employees and officers of the Company. Any employee found not to be adhering to these policies and procedures will face severe disciplinary action. It is the policy of the Company and its Collaborators to prohibit and actively prevent money laundering and any activity that facilitates money laundering or the funding of terrorist or criminal activities.
Due to the cross-border nature of the transactions the international legal framework for anti‐money laundering consists of a number of sources represented by international conventions, the FATF Recommendations, European as well domestic law provisions. The following list the main reference rules for the Company, in relation to the countries in which it operates under the right of establishment.
FAFT Recommendations
Recommendations of FATF – FATF IX Special Recommendations, FATF 40 Recommendations.
They represent the fundamental standards on preventing and combating money laundering and terrorism financing, to which other international bodies, the European Union and individual Member State refer.
Community ‐ EU
EU Directive – 2015/849 – IV Anti‐ money laundering.
It sets out measures for preventing and combating money laundering and terrorism financing, acknowledging, over time, the evolution of international standards with the aim of achieving a harmonised regulatory environment between the Member States.
Domestic law of St. Vincent and the Grenadines
- The Proceeds of Crime Act, No. 38 of 2015;The Financial intelligence Unit Act, Cap 174 of the Revised Laws of 2009, as amended by Act No. 7 of 2013.
- The Drug Trafficking Offenses Act, Cap 173 of the Revised laws of 2009.
- The Exchange of Information Act, cap 146 of the Revised Laws of 2009.
- The Proceeds of Crime and Money Laundering (Prevention) Act, 2001.
- The Proceeds of Crime and Money Laundering Regulations, 2002.
- The Financial Intelligence Unit Act, 2001.
- The Mutual Assistance in Criminal Matters Act, cap 177 of the Revised Laws of 2009.
- The Anti- Money laundering and Terrorist Financing Regulations, No. 20 of 2014.
- The Confiscation in the Magistrates’ Court Regulations, No. 22 of 2015.
St. Vincent and the Grenadines has implemented a package of legislation aimed at detecting, preventing, and prosecuting money laundering and other serious crimes as well as confiscating the profits of crime. The legislative measures reflect international best practices and take account of the 40 Recommendations of the Financial Action Task Force (FATF) on money laundering and the 19 Recommendations of the Caribbean FATF. The regulatory body with the mandate to supervise the offshore financial sector is the Financial Services Authority.
The above-mentioned provisions are likely to be amended / integrated / replaced following the full transposition ‐ in the jurisdictions in which the Company operates – of EU Directive ‐ 2015/849 “IV Anti‐Money Laundering Directive”.
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