Sterling Gent Trading Ltd (SGT) is committed to the fight against money laundering.
As part of our regulatory obligation and our efforts to combat money laundering, we have appointed an officer that is responsible for Anti-Money Laundering and is accountable to senior management. SGT requires all relevant personnel to complete training in Anti-Money Laundering and our internal Compliance Procedures.
The Money Laundering Reporting Officer ("MLRO")
The MLRO’s functions is to receive all reports of suspicious activities from staff.
The MLRO is responsible for overseeing the implementation of the policies and procedures set out in this AML Policy, determining whether and to what extent to report suspicious activities to the BVI Financial Investigation Agency (the “FIA”), responding to requests made by the FIA for information, and resolving any issues or differences of opinion arising out of this AML Policy.
The Financial Investigation Agency
In the BVI, reports on money laundering and terrorist financing activities are made to the Financial Investigation Agency (“FIA”) set up under the Financial Investigation Agency Act, 2003.
Four Key Policies
SGT has in place four primary policies that are designed to assist in the recognition, prevention, and reporting of money-laundering activities. We summarise these as follows:
Policy 1: Know Your Client (“KYC”)
Policy 2: Beneficial Owner Verification (“BOV”)
Policy 3: Suspicious Activities Reporting
Policy 4: Systems, Controls, and Training
The BVI Legislation
Anti-money laundering legislation in the BVI, and indeed worldwide, recognises the use of professional services for money laundering. The AML (Anti-Money Laundering) and CFT (Combating the Finance of Terrorism) laws in various jurisdictions have therefore been extended to apply beyond the traditional, regulated institutions to include independent legal professionals and trust and company service providers.