KYC / COMPLIANCE POLICY

KYC / COMPLIANCE POLICY

KYC / Compliance Policy of GTC

Procedures for New Accounts

When a business relationship is being established, the nature of the business that the customer expects to conduct with GTC should be ascertained at the outset to show what might be expected as normal activity. In order to be able to judge whether a transaction is or is not suspicious, GTC compliance needs to have a clear understanding of the legitimate business of their customers.

With the increased competition between brokerage houses, seen in recent years, the need to develop new business has become paramount. Care must, however, be exercised when opening new accounts either for Institutional, businesses or private individuals. Customer references have to be themselves checked for authenticity and reliability. GTC staff are duty bound to record detailed evidence of each customer’s identity. The nature of the identity given to us should be photocopied and retained in our records along with the relevant dates when it was submitted. Where facilities are required, we must know the precise purpose (and subsequently check to see that the facility has been used for that purpose) and, of course, the terms and source of repayment or settlement of the facility. It is advisable, from time to time, to call on the business premises to see if it appears to be, prima facie, conducting itself within the description given to the GTC E.g. manufacturer, Producer. hedger, retail trader, etc. It should be noted that corporate accounts are one of the most likely vehicles for money laundering.

Notes should always be prepared when customer contact has taken place, be it in person at either the GTC or the customer’s premises or over the telephone. Such is admissible as evidence in a court of law. The evidence of a customer closing his account must be retained for five years and these should include details of how the transaction which closed the account was handled so that an audit trail is in place.

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