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ANTI-MONEY LAUNDERING & SANCTIONS STATEMENT
To protect Dreamline’s Commodities (here and after, “Dreamline”) reputation and to be in compliance with legislation requirements, it is important not to become associated or be blindly involved with the criminal activities of other privates and/or legal entities.
In particular, employees must ensure Dreamline is in compliance with economic sanctions laws and regulations, and deal with no proceeds of criminal activities. This Statement sets out essential steps that employees take to avoid breaching sanctions rules or being involved in money laundering.
The Anti-Financial Crime Compliance Policy of Dreamline is a key pillar in combating money laundering and the financing of terrorism, and assuring compliance with economic sanctions regimes.
Pursuant to the provisions of the Policy, any employee, having the knowledge that the funds are the proceeds of a felony or a misdemeanor, and who willfully commits any of the following acts, shall be considered an involved of the crime of money laundering:
- transferring or moving proceeds or conducting any transaction with the aim of concealing or disguising their illegal source;
- acquiring, possessing or using proceeds upon receipt; or
- assisting the perpetrator of the offense to escape punishment.
Dreamline’s employees are to:
1. Comply with the Anti-Financial Crime Compliance Policy, the Global Economic Sanctions Standard, and any local anti-money laundering or sanctions procedures, when they onboard, contract or monitor customers, counterparties or any third parties involved.
2. Immediately notify the Group Compliance Officer if they have any suspicions about actual or potential money laundering activity or about transactions with sanctioned countries or sanctioned third parties.
3. Obtain prior clearance from the Group Compliance Officer and/or Senior Business Partners before allowing any of the following events to happen:
Customer or Counterparty requests Dreamline to:
- Pay funds to a bank account in the name of a different third party,
- Take payments in a form outside the normal terms of business,
- Split payments to several bank accounts or several banks,
- Overpay.
Customer or Counterparty payments to Dreamline:
- From multiple bank accounts,
- From bank accounts from a different geography,
- Deposited in cash when normally made by cheque or wire,
- Received from not onboarded third parties and/or not part of the contract,
- Paid in advance when not part of normal terms of business (or as mistake).
Dreamline’s employees involved in engaging or contracting with third parties such as new suppliers, customers and/or counterparties are to:
- Ensure that the third parties in question are subject to screening to assess their identity and legitimacy before contracts are signed or transactions occur. Various factors will determine the appropriate forms and levels of screening,
- Determine, with guidance from the Compliance Officer, which tools and processes should be used to facilitate appropriate screening and record-keeping,
- Carefully consider, where necessary in consultation with the Compliance Officer, screening outcomes before deciding whether to do business with the third party,
Finance and business managers who support business management and customers development must regularly monitor and / or review suppliers, customers and other third-party service providers to identify business activity or governance that could indicate money laundering is taking place.
Dreamline’s employees are not to:
• Simply assume relevant third-party screening has already taken place: failure to check or update screenings periodically may put Dreamline and its employees at risk;
• Inform a third party suspected of money laundering that they are subject of an internal or external investigation: employees must obtain guidance from the Group Compliance Officer on how to handle the matter with the third party.