Money Laundering Prevention Policy for Travel et Vogue

 

1. Introduction

Travel et Vogue is committed to conducting its business with integrity and in compliance with all applicable laws and regulations, including those related to anti-money laundering (AML) and combating the financing of terrorism (CFT). This policy outlines Travel et Vogue's approach to preventing money laundering and sets forth the procedures and controls to be followed by all employees.

 

2. Responsibilities

 

2.1 Management: The management of Travel et Vogue is responsible for ensuring that adequate AML/CFT policies and procedures are in place and effectively implemented throughout the organization.

 

2.2 Employees: All employees are required to familiarize themselves with this policy and comply with its provisions. They should report any suspicious activities or transactions to the designated compliance officer.

 

2.3 Compliance Officer: A designated compliance officer will oversee the implementation of this policy, conduct regular risk assessments, provide training to employees, and ensure that appropriate controls are in place.

 

3. Customer Due Diligence (CDD)

 

3.1 Identification: Travel et Vogue will conduct thorough customer due diligence to verify the identity of all customers, including individuals and entities, before establishing a business relationship or conducting any transactions.

 

3.2 Risk-Based Approach: Customer due diligence measures will be commensurate with the assessed risk level of the customer, considering factors such as the nature of the business, location, and transactional patterns.

 

3.3 Enhanced Due Diligence (EDD): Enhanced due diligence will be conducted for high-risk customers, including politically exposed persons (PEPs) and customers from high-risk jurisdictions, to obtain additional information and monitor transactions more closely.

 

4. Transaction Monitoring

 

4.1 Suspicious Activity Monitoring: Travel et Vogue will implement systems and procedures to monitor transactions for unusual or suspicious activity, including transactions that do not have an apparent business or lawful purpose.

 

4.2 Reporting: Employees are required to promptly report any suspicious transactions or activities to the compliance officer, who will assess the report and, if necessary, file a suspicious activity report (SAR) with the relevant authorities.

 

5. Record-Keeping

 

5.1 Documentation: Travel et Vogue will maintain accurate and up-to-date records of all customer transactions, including identification documents, transaction history, and any other relevant information.

 

5.2 Retention Period: Records will be retained for a period of at least five years from the date of the last transaction or the end of the business relationship, whichever is later, in accordance with applicable laws and regulations.

 

6. Training and Awareness

 

6.1 Training Program: Travel et Vogue will provide regular training to employees on AML/CFT laws, regulations, and internal policies and procedures to ensure they understand their obligations and can effectively identify and report suspicious activities.

 

6.2 Awareness: Employees will be encouraged to remain vigilant and report any concerns or suspicions regarding money laundering or terrorist financing to the compliance officer.

 

7. Compliance Monitoring and Review

 

7.1 Regular Reviews: Travel et Vogue will conduct regular reviews of its AML/CFT policies, procedures, and controls to assess their effectiveness and make any necessary updates or improvements.

 

7.2 Independent Audits: Periodic independent audits will be conducted to evaluate the company's compliance with this policy and applicable AML/CFT regulations.

 

8. Conclusion

 

Travel et Vogue is committed to preventing money laundering and terrorist financing activities and will continue to implement robust policies, procedures, and controls to ensure compliance with all relevant laws and regulations. All employees are expected to adhere to this policy and play their part in maintaining the integrity of the company's operations.

 

This policy will be communicated to all employees and made available on the company's internal network for easy reference. Any questions or concerns regarding this policy should be directed to the compliance officer.