Anti-money laundering and counter-terrorism financing (“AML/CTF”) policy

Table of Contents

Parker Winston Eckhardt Pty Ltd (ACN: 646 396 527) (“PWE Capital”) is committed to conducting its  business in accordance with all applicable laws and regulations, and in a way that enhances its  reputation in the market. This policy records PWE Capital’s approach to the identification, mitigation  and management of the risk that PWE Capital’s products and services might be involved in the  facilitation of money laundering or the financing of terrorism.

Description of money laundering and terrorism financing

PWE Capital defines money laundering (“ML”) as activity which is designed to conceal or disguise the true  origin of criminally derived proceeds in order to make them appear to have been sourced from legitimate  sources.  


Terrorist Financing (“TF”) is considered to be the act of providing financial support to terrorism or terrorist  organisations to enable them to carry out acts of terrorism. 

Objectives of PWE Capital’s AML/CTF policy

PWE Capital has established an AML/CTF policy which sets the core principles for the management of  ML/TF risk. The policy is global in nature and outlines group-wide standards to meet regulatory and  ethical obligations in the economies in which PWE Capital does business. This contributes to the  stability, integrity and strength of the global financial system and protects PWE Capital from  reputational damage and regulatory action. The Policy is subject to regular review to ensure it remains  current with regulator expectations and industry standards  

The core principles

PWE Capital has adopted the following core principles:  


PWE Capital opposes the crimes of money laundering and terrorist financing and maintains a  framework to identify and mitigate the risk that its products and services could be used for such  purposes.  


PWE Capital reports any activity that it detects which is suspicious and may involve potential money  laundering or terrorism financing to the applicable regulator.  


PWE Capital will comply with the AML/CTF laws, rules and regulations of the countries that relate to  AML/CTF where PWE Capital has permanent places of business through which PWE Capital provides services.  


PWE Capital will endeavour to provide its products and services only for legitimate purposes to  customers whose identities PWE Capital has been able to reasonably ascertain.  


PWE Capital will take reasonable steps to ensure that sufficient funding and resources are available  for the implementation and performance of activities required by PWE Capital’s AML/CTF Program.  • PWE Capital’s employees are required to attend AML/CTF training to understand their obligations  under the relevant laws, rules and regulations.  


PWE Capital will monitor its customers, their transactions, and its employees, consistent with the  level of money laundering and terrorist financing risk they represent.  


PWE Capital will manage new and revised changes to PWE Capital’s products, business processes  and systems to ensure that money laundering and terrorist financing risks are identified and  managed.

Know Your Customer ("KYC")

PWE Capital endeavours to follow all KYC policies and procedures relevant to the regions in which it operates. Applicable KYC policies and procedures to establish and verify the identity and bona fides of  customers will also be complied with.  


These will include:  


Customer acceptance procedures that identify types of customers and transactions likely to pose a  higher than average risk to PWE Capital and require a higher level of due diligence;  • Procedures to establish if customers are known or suspected money launderers, terrorists or  otherwise engaged in criminal activity (e.g. reviewing customers against government/United  Nations/regulators’ lists of proscribed persons);  


Enhanced Due Diligence undertaken where a transaction or a counterparty results in a heightened  level of financial crime or reputational risk; 


A risk-based periodic review of existing customer records to maintain currency and completeness;  • Ongoing monitoring of transactions conducted by customers using a risk based approach;  • Procedures prohibiting accounts/relationships, including payment processing, with shell banks; • A clear statement on what records must be kept on customer identification and individual  transactions and their retention period; and  


Regular compliance reviews and independent audits of AML/CTF program and procedure  documents and execution against established standards.  

Suspicious Activity

PWE Capital staff are trained and made aware of “red flags”, or anything that is unusual or out of the  ordinary when dealing with customers and customer related information. PWE Capital has the relevant  procedures and processes in place to ensure that any genuinely suspicious matters are detected and  escalated for review by senior management.

PWE Capital’s AML/CTF training program

PWE Capital has a robust AML/CTF Training Program to educate employees in implementing and  maintaining PWE Capital’s AML/CTF Program. All employees undergo initial AML/CTF training when  they join PWE Capital. In addition, there are ongoing training requirements for all employees.  

PWE Capital’s record retention

PWE Capital’s Record Management Policy requires retention of records for as long as required by  applicable laws, rules and regulations.  

Independent review of the AML/CTF program

PWE Capital’s AML/CTF Program is subject to independent review in accordance with the requirements  of each local jurisdiction. The results of the review are presented to senior management for review and  action. In addition, regular reporting is provided by Compliance to PWE Capital’s Board.  

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© PWE Capital 2020. All Rights Reserved. PWE Capital, Redefining R.O.I. and the PWE waves logo are registered Trademarks of Parker Winston Eckhardt PTY LTD. (ACN: 646 396 527)

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