Anchor Investment Mangement Ltd. is committed to maintaining the highest standards of integrity in its business as a Bermuda Regulated Financial Institution. Customers and employees should feel confident that Anchor not only administers its business in full compliance with the law but also actively seeks to play a positive role as a reputable corporate citizen to further the goals behind the law.

In Bermuda there has been a long-standing obligation to have effective procedures in place to detect and prevent money laundering and terrorist financing. The offence of money laundering is contained in the Proceeds of Crime Act of 1997, as amended and obligations to combat terrorist financing are set out in the Anti-Terrorism (Financial and Other Measures) Act 2004.

Prevention is at the heart of any AML and ATF measures. The key focus of prevention is conducting Customer Due Diligence (“CDD”) and getting to ‘know your client’ (“KYC”), that they really exist and that they are who they say they are. This means taking reasonable steps to confirm the identity and legitimacy of potential customers and investigating and/or reporting instances when a current or prospective customer appears to be engaging in unusual or suspicious transactions. Risks associated with potential customers, product offerings, delivery channels, geographic and activity risks were considered in developing Anchor’s AML/ATF policies and procedures.

Consistent with Bermuda law, the policies and procedures outlined here require:

  • Adoption of a formal policy in relation to the prevention and detection of money laundering and terrorist financing;
  • Reasonable steps to be taken in order to verify the identity of persons and entities with which Anchor does business with through forms of due diligence given the risk ranking of the client or potential client;
  • Guidelines referring to the use of standard or enhanced due diligence given certain levels of risk prescribed to the client;
  • Maintaining records about clients and financial transactions by Anchor and its advisors and/or agents;
  • Monitor transactions based on the customer risk ranking;
  • Internal reporting procedures and guidelines for reporting of suspicious activities to the FIA and appointment of a Compliance Officer (“CO”) and a Reporting Officer (“RO”);
  • Training of all relevant employees; and
  • Co-operation with governmental investigation and enforcement efforts.
The key overarching framework guiding these policies and procedures is the Business Risk Assessment (“BRA”). Anchor expects all managers and staff to comply with the following core principles in the conduct of their daily business and in regard to AML/ATF monitoring and reporting in conjunction with the BRA:
  • Anchor is committed to maintaining a culture and value system that takes all AML/ATF issues seriously and with the utmost importance;
  • Anchor is committed in using a Risk Based approach throughout its Compliance Program.
  • Anchor is committed to hiring and retaining only employees who follow these principles;
  • Staff and managers are encouraged, at any time to voice concerns and/or ask questions pertaining to any matter involving AML/ATF issues or situations promptly and internally;
  • Anchor is committed to ensuring that all customers’ identities are satisfactorily verified before Anchor accepts them as clients;
  • Anchor is committed to ‘knowing its customers’ appropriately - both at acceptance and throughout the business relationship - through taking appropriate steps to verify the customer’s identity and business, and his/her reasons for seeking the particular business relationship with the institution;
  • Anchor is committed to monitoring transactions consistent with their risk ranking;
  • Anchor is committed to ensuring that staff are trained and made aware of the law and their obligations under it, and to establishing procedures to implement these requirements; and
  • Anchor is committed to periodic and independent auditing to test the effectiveness of its AML/ATF procedures and controls to address any shortcomings in a timely manner.
Last updated: March 1 2021

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