The policy establishes Centinel Securities’ framework for preventing money laundering and terrorist financing under the SECP AML/CFT Regulations and related guidance. It adopts a risk-based approach so that controls, staffing and monitoring are proportionate to the risks presented by customers, geographic locations, products, transactions and delivery channels.
Customer identification and due diligence are central to the framework. The company must verify identity documents, understand sources of income, identify beneficial owners and establish the purpose of each relationship. Customers and related parties are screened against applicable sanctions and proscribed-person lists, while higher-risk relationships are subject to enhanced review and ongoing monitoring.
The framework uses three lines of defence. Customer-facing and operational teams apply controls in daily work; compliance, risk, finance, HR and IT provide oversight and support; and Internal Audit with the Board Audit Committee independently tests the system. A designated Compliance Officer reports to the Board and coordinates with relevant authorities.
Employees must identify and internally report suspicious activity without alerting the customer. The policy also addresses sanctions compliance, record retention, staff screening, continuing training, periodic risk assessments and independent audits.
This summary is for convenience and does not replace the approved document. If there is any difference, the complete PDF governs.