Anti-Money Laundering Policy

Whitford Worldwide and all wholly owned or controlled Whitford Worldwide companies are committed to implementing a single global standard shaped by the most effective anti-money laundering standards available in any location where Whitford operates.

Whitford has established a Global Anti-Money Laundering Program (“AML Program”) for this purpose. The objective of the AML Program is to ensure that money-laundering risks identified by Whitford are appropriately managed. This is achieved by establishing Board-approved, minimum governing policies, principles, and standards and implementing appropriate controls, to protect Whitford, its employees; shareholders and customers from money laundering. The AML Program provides guidance to all Whitford employees, requiring them to conduct business in accordance with applicable AML laws, rules, and regulations.

The AML Program is based upon various laws, regulations and regulatory guidance from the United Kingdom, the European Union, Hong Kong, the United States of America, and, as applicable, local jurisdictions in which Whitford does business.

The Program includes but is not limited to:

  • The appointment of a Global and Country Money Laundering Reporting Officer (“MLRO”) or alternative position as required by local regulation.
  • A Customer Due Diligence (“CDD”) Program, which incorporates Customer Identification and Verification (“ID&V”) and Know Your Customer (“KYC”) principles, and the implementing of programs designed to review our existing customers.
  • Conducting enhanced due diligence (“EDD”) on customers assessed as higher risk, such as Politically Exposed Persons (“PEPs”) in senior positions, their relatives and close associates.
  • Establishing processes and systems designed to monitor customer transactions for the purpose of identifying suspicious activity.
  • The investigation and subsequent reporting of suspicious activity to the appropriate regulatory bodies.
  • Regular AML training of its employees and contractors.
  • The prohibition of the following products, services and customer types:
    • Anonymous accounts or numbered accounts or customers seeking to maintain an account in an obviously fictitious name.
    • Shell businesses, i.e. businesses with no physical presence or staff.
    • Hold Mail, i.e. where the customer has instructed all documentation related to the account are to be held on their behalf until collection.
    • Payable-through-accounts, i.e. Whitford does not allow domestic or foreign customers to provide payable-through-accounts to their customers; and
    • Any relevant additional local requirements including complying with the UK Criminal Finances Act 2017.