Anti-Money Laundering (AML) and Counter Terrorism Financing (CFT) Policy

Aml Lhfx

LHFX is a trading name of Longhorn Ltd, a company incorporated in Mauritius and authorized and regulated by the Financial Services Commission (FSC) Mauritius under the Investment Dealer license number GB23202204, Code SEC-2.1B. Our office is located at Suite 102, 1st Floor, Sterling Tower, 14 Poudriere Street, Port-Louis, Mauritius.


This Anti-Money Laundering (AML) and Counter Terrorism Financing (CFT) policy outlines the framework and procedures that LHFX adheres to, in compliance with Mauritius governing laws, specifically the Financial Intelligence and Anti-Money Laundering Act 2002, as amended, and other relevant regulations and guidelines issued by the Financial Services Commission (FSC) Mauritius.


Definitions and Interpretations

Money Laundering: The process of concealing or disguising the origins of money obtained through illegal activities, making it appear as though it originated from legitimate sources.

Terrorism Financing: The provision of funds, directly or indirectly, for terrorist activities.

Client Due Diligence (CDD): The process of identifying and verifying the identity of clients and understanding the nature and purpose of the business relationship.

Beneficial Owner: A natural person who ultimately owns or controls a client or the person on whose behalf a transaction is conducted.

Politically Exposed Person (PEP): An individual who is or has been entrusted with a prominent public function, their immediate family members, or persons known to be close associates of such individuals.


Money Laundering

LHFX recognizes the importance of preventing money laundering and the financing of terrorism. We are committed to complying with the Financial Intelligence and Anti-Money Laundering Act 2002, and other relevant regulations to prevent, detect, and report money laundering and terrorist financing activities.


Client Due Diligence (CDD)

LHFX implements stringent CDD measures to verify the identity of our clients and to understand the nature and purpose of the business relationship. These measures include:

1. Identification and Verification:

- For natural persons: Obtaining and verifying the client's name, address, and identification documents such as national identity card, passport, or other official documents.

- For legal entities: Identifying the beneficial owner, the entity's legal form, headquarters address, directors, principal owners, beneficiaries, and control structure.

2. Risk Assessment:

- Assessing the risk profile of each client based on factors such as their geographic location, nature of business, transaction patterns, and other relevant factors.

- Categorizing clients into risk levels (low, medium, high) to determine the appropriate level of due diligence.

Client Risk Assessment

LHFX conducts a risk assessment of all clients to identify those that may pose a higher risk of money laundering or terrorist financing. This assessment includes:

- Evaluating the client's geographic location, type of business, and transaction patterns.

- Determining whether the client is a politically exposed person (PEP) or has links to high-risk jurisdictions.

Simplified Due Diligence (SDD)

For clients assessed as low risk, LHFX may apply simplified due diligence measures, which include:

- Collecting basic identification information.

- Conducting periodic reviews to ensure the client's risk profile remains low.

Enhanced Due Diligence (EDD)

For clients assessed as high risk, LHFX applies enhanced due diligence measures, which include:


- Obtaining additional identification and verification documents.


- Conducting more frequent and thorough reviews of the client's activities and transactions.

- Seeking senior management approval before establishing or continuing the business relationship.

Source of Funds and Source of Wealth

LHFX ensures that the source of funds and source of wealth of our clients are legitimate by:


- Requesting clients to provide information and documentation on the origin of their funds.


- Verifying the provided information through independent sources when necessary.

Verification

LHFX employs robust verification procedures to confirm the identity of our clients. These procedures include:


- Utilizing reliable and independent sources for document verification.


- Cross-checking information provided by clients with external databases and watchlists.

Ongoing CDD and Transaction Monitoring

LHFX maintains ongoing CDD and transaction monitoring to detect and report suspicious activities. This includes:


- Continuously updating and verifying client information.


- Monitoring client transactions for unusual or suspicious patterns.


- Reporting any suspicious activities to the Financial Intelligence Unit (FIU) in accordance with the Financial Intelligence and Anti-Money Laundering Act 2002

Record Keeping

LHFX maintains comprehensive records of all client identification and verification documents, transaction records, and reports of suspicious activities. These records are kept for at least seven years, in compliance with the Financial Intelligence and Anti-Money Laundering Act 2002.

Reporting Suspicious Activities

LHFX is committed to reporting any suspicious activities to the Financial Intelligence Unit (FIU) without delay. Employees are trained to recognize and report suspicious activities in accordance with established procedures.

Compliance with Mauritius Laws and Regulations

LHFX ensures full compliance with all relevant laws and regulations in Mauritius, including:


- Financial Intelligence and Anti-Money Laundering Act 2002


- Guidelines and directives issued by the Financial Services Commission (FSC) Mauritius


- Other applicable international AML & CFT standards

Conclusion

LHFX is committed to maintaining the highest standards of AML & CFT compliance. Our policies and procedures are designed to detect, prevent, and report money laundering and terrorist financing activities, ensuring the integrity of our operations and the financial system.

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