Effective Date: 13 December 2024
Company: Alser Limited
Registered Address: One Capital Place 7B, 18 Luard Road, Wan Chai, Hong Kong
Company Registration Number: 77464566
1. Introduction
Alser Limited (“Company”, “we”, “us”) is committed to maintaining the highest standards of compliance with applicable anti-money laundering (“AML”) and counter-financing of terrorism (“CFT”) regulations. This AML Policy outlines the measures we take to prevent the use of our platform for money laundering, terrorist financing, and other illegal activities.
This policy is designed to comply with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) of Hong Kong and other relevant international standards.
2. Scope and Purpose
2.1. Applicability: This policy applies to all employees, contractors, partners, and clients of Alser Limited. It governs all interactions, transactions, and activities conducted through our platform and services.
2.2. Objective: Our primary goals are:
• To prevent and detect money laundering and terrorist financing activities.
• To protect the integrity and reputation of our business.
• To ensure compliance with all applicable AML/CFT laws and regulations.
2.3. Risk-Based Approach: Alser Limited adopts a risk-based approach (RBA) to AML compliance, ensuring resources are focused on areas of higher risk.
3. Know Your Customer (KYC) and Client Due Diligence (CDD)
3.1. KYC Requirements: Before engaging in any transactions, all clients must complete our KYC process, which includes:
• Verification of business registration documents.
• Identification of authorized representatives.
• Proof of address for the business entity.
3.2. Enhanced Due Diligence (EDD): For high-risk clients, additional information may be required, such as:
• Source of funds.
• Details of beneficial ownership.
• Nature of the client’s business activities.
3.3. Ongoing Monitoring: Transactions and client activities are monitored on an ongoing basis to identify and report any suspicious activity. Clients are required to update their information periodically.
4. Transaction Monitoring and Reporting
4.1. Transaction Screening: All transactions are screened against international sanctions lists and monitored for unusual or suspicious patterns, such as:
• Large, unexpected, or irregular transactions.
• Transactions originating from or destined for high-risk jurisdictions.
• Multiple smaller transactions designed to avoid reporting thresholds.
4.2. Suspicious Transaction Reporting: Any transaction or activity deemed suspicious will be reported to the relevant authorities in compliance with AMLO requirements.
4.3. Record Keeping: We maintain detailed records of all transactions, customer interactions, and compliance activities for a minimum of seven (7) years, as required by law.
5. Training and Awareness
5.1. Employee Training: All employees and contractors are required to undergo regular AML/CFT training to:
• Recognize red flags and indicators of money laundering.
• Understand reporting obligations and procedures.
• Stay informed about changes in AML/CFT laws and regulations.
5.2. Management Accountability: Senior management oversees the implementation and effectiveness of this policy and ensures all personnel adhere to its requirements.
6. Data Protection and Confidentiality
6.1. Data Security: All customer and transaction data is handled in compliance with Hong Kong’s Personal Data (Privacy) Ordinance (PDPO). Measures are in place to ensure data security and confidentiality.
6.2. Confidential Reporting: Suspicious transaction reports are handled confidentially and shared only with the appropriate authorities, as required by law.
7. Prohibited Activities
7.1. Illegal Transactions: Alser Limited strictly prohibits engaging in any transactions involving proceeds from criminal activities or those designed to finance terrorism.
7.2. Sanctioned Parties: We do not conduct business with individuals, entities, or countries subject to international sanctions.
8. Governance and Oversight
8.1. Compliance Officer: Alser Limited has appointed a dedicated Compliance Officer responsible for:
• Developing and implementing AML/CFT policies.
• Ensuring compliance with regulatory obligations.
• Serving as the point of contact with regulatory authorities.
8.2. Policy Review: This AML Policy is reviewed and updated annually or as required to reflect changes in regulations or business operations.
9. Reporting Concerns
Clients, employees, and partners are encouraged to report any concerns or suspicious activities to our Compliance Officer. Reports can be made confidentially via email at [compliance@alserdigital.com].
10. Non-Compliance and Penalties
Failure to comply with this AML Policy may result in severe consequences, including termination of business relationships, legal action, and reporting to regulatory authorities.
Contact Information:
For questions or additional information about this AML Policy, please contact us at:
Email: info@alserdigital.com
Address: One Capital Place 7B, 18 Luard Road, Wan Chai, Hong Kong
