Effective Date: January 1, 2025
Last Updated: January 1, 2025
NBR. Company Ltd. (“NBR”, “we”, “our”, “us”) is committed to conducting business with the highest standards of integrity, transparency, and regulatory compliance. This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy (“Policy”) sets out the framework, procedures, and responsibilities for preventing money laundering, terrorist financing, and financial crime across all NBR services and operations.
1. Purpose
The purpose of this Policy is to:
- Ensure compliance with all applicable AML and KYC laws, regulations, and international standards.
- Prevent NBR from being used, intentionally or unintentionally, for money laundering, terrorist financing, or other illicit financial activities.
- Protect NBR’s reputation, assets, and clients by maintaining a transparent and secure financial ecosystem.
2. Scope
This Policy applies to:
- All NBR business units, subsidiaries, and offices globally.
- All employees, contractors, consultants, and affiliates who engage with clients, process payments, or handle financial transactions.
- All clients, partners, and counterparties engaging in financial, consulting, or digital services with NBR.
3. Definitions
- Money Laundering: The process of concealing the origins of illegally obtained funds to make them appear legitimate.
- Terrorist Financing: Providing or collecting funds to support terrorist activities, irrespective of the source.
- Client: Any individual, entity, organization, or intermediary that engages NBR’s services or enters into a contractual relationship.
- Politically Exposed Person (PEP): An individual with prominent public functions, along with their immediate family and close associates, posing potential higher risk for bribery or corruption.
4. KYC Procedures
NBR implements comprehensive Know Your Customer procedures to verify and assess client identity and risk, including:
4.1 Client Identification
- Collection of full legal name, date of birth or incorporation, nationality, and permanent address.
- Verification of identification documents (government-issued ID, passports, corporate registration certificates).
- Verification of ownership and control structure for corporate entities.
4.2 Client Due Diligence (CDD)
- Assessment of risk profile based on geographic location, industry, transaction volume, and client history.
- Enhanced Due Diligence (EDD) for high-risk clients, including PEPs or jurisdictions with higher corruption or money laundering risks.
- Ongoing monitoring and review of client activity to detect unusual or suspicious transactions.
4.3 Risk-Based Approach
- Clients are categorized into low, medium, or high-risk profiles.
- Frequency and depth of monitoring are proportionate to assessed risk levels.
- Higher-risk clients may be subject to additional verification, approvals, or transaction restrictions.
5. Transaction Monitoring
- All transactions, whether financial, advisory, or digital, are monitored for unusual patterns, anomalies, or red flags.
- Automated and manual monitoring tools are utilized to detect irregular activities.
- Suspicious transactions are escalated to the Compliance Officer for review.
6. Reporting Obligations
- Any activity suspected to involve money laundering, terrorist financing, or other illicit activity must be reported immediately to the NBR Compliance Officer.
- Compliance Officer is responsible for reporting to the relevant authorities in accordance with applicable law.
- Employees are protected from retaliation for reporting in good faith.
7. Record-Keeping
- NBR maintains detailed records of client identification, transactions, risk assessments, and due diligence activities.
- Records are retained for a minimum period as required by applicable laws and regulations.
- Documentation must be accessible for regulatory inspections or audits.
8. Employee Responsibilities
- All employees must complete AML and KYC training upon onboarding and at regular intervals.
- Employees must comply fully with this Policy, report suspicious activities, and cooperate with internal audits or investigations.
- Violations may result in disciplinary action, including termination and potential legal consequences.
9. Governance and Oversight
- NBR appoints a dedicated Compliance Officer responsible for implementing and maintaining AML/KYC controls.
- Periodic audits, risk assessments, and policy reviews ensure ongoing effectiveness.
- Executive management reviews reports and metrics related to AML and KYC compliance regularly.
10. Risk Mitigation Measures
- Implementation of robust internal controls to prevent fraud, corruption, and money laundering.
- Continuous monitoring of regulatory changes and industry best practices.
- Collaboration with banks, financial institutions, and regulatory authorities as necessary.
11. Breach and Enforcement
- Any breach of this Policy must be reported immediately.
- NBR will investigate breaches thoroughly and implement corrective measures.
- Legal and regulatory action may be pursued in cases of non-compliance by clients, employees, or partners.
12. Review and Updates
- This Policy is reviewed annually or whenever required by changes in law, business operations, or risk environment.
- Updates are communicated to all employees, contractors, and relevant stakeholders.
13. Contact
For questions or concerns regarding AML & KYC compliance, please contact:
NBR. Company Ltd.
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📧 support@nbr.company
