AML Policy

Updated: January 2024

1. Introduction

It is the Company’s policy that the applicable statutory and regulatory obligations to prevent money laundering and funding of terrorism are to be met in full. The Company is committed to meeting, and where possible exceeding, such expectations. Positive management action will be exercised to minimize the risk of the Company’s services being abused for the purposes of laundering funds associated with criminal activity, as defined by the relevant legislations.

The Company’s approach is based upon the following legal frameworks:

  • The International Framework: The Financial Action Task Force (“FATF”) is the globally recognized body for assessing AML/CFT standards. Reference is made to the FATF’s guidance for a risk-based approach to virtual assets and virtual assets service providers.
  • Isle of Man Legislative Background: By virtue of being included in the Schedule 4 of POCA, a convertible virtual currency business in Isle of Man is subject to ‘The Anti-Money Laundering and Countering the Financing of Terrorism Code 2019’, ‘Designated Businesses (Registration and Oversight) Act 2015’, ‘Financial Services Act 2008’, and the ‘Proceeds of Crime Act (Business in the Regulated Sector) Order 2019.
2. Onboarding and Customer Due Diligence Measures

Customer Due Diligence Procedures must be completed before the signing of any agreement with a new customer. Furthermore, all Customer Due Diligence must be provided, and contracts are to be fully signed prior to any customer being permitted to enable their account and to use Arrows Global’s Services.

In accordance with the relevant legislations, Arrows Global will:

  • Identify the purpose and intended nature of the business relationship.
  • Identify and verify the customer based on documents or using sources deemed reliable.
  • Where it appears that a person is not acting on his own behalf, appropriate inquiries should be made to determine on whose behalf that person (the “agent”) is acting, and additional customer due diligence measures must be carried out.
  • In certain other circumstances, which present a high risk of ML/FT, the Company must apply enhanced due diligence measures.

The kind of information gathered will vary depending on the risk profile of the customer and the service identified through the customer risk assessment.

3. Ongoing Monitoring

The Company is required to carry out ongoing monitoring with respect to customers with whom it has an ongoing business relationship. The scope of scrutiny of transactions is to:

  • Identify behavior or transactions which diverge from the usual pattern of transactions, do not fit within the customer’s profile, or are otherwise not in line with what is normally expected from the customer, and which therefore need to be questioned in further detail.
  • Identify suspicious activity in relation to which a STR is to be filed with the FIU
  • Determine whether the initial risk assessment requires updating, and whether, in view of the updated risk assessment or other considerations, the business relationship remains within the risk appetite of the subject person and, if so, understand whether the level of CDD needs to be adjusted in view of any changes from the initial risk understanding.

Furthermore, Arrows Global shall conduct periodic reviews on the documents and data held on file to ensure that customer files are always kept up to date.

4. Country and Industry Restrictions

The Company has adopted policies designed on lists issued by the FATF, the European Union Commission Delegated Acts on High Risk Third Countries, and other organisations issuing guidelines and lists relating to the adequacy of legislative measures adopted by jurisdictions in relation to money laundering, funding of terrorism and transparency.

Enhanced due diligence and applicable controls shall be applied in the case of any customers who reside / are incorporated in the ‘High Risk Countries’ in accordance with Arrows Global’s AML Policy.

If a customer is identified as operating in any of the industries defined as prohibited by Arrows Global, the Company shall not enter a business relationship with them or seek to terminate the present ongoing relationship. Enhanced due diligence and applicable controls shall be applied in the case of any customers engaged in industries identified by the Company as ‘High Risk’.

5. Country and Industry Restrictions

The retention period for transaction records and customer documentation shall be in accordance with the applicable regulatory requirements.