ANTI-MONEY LAUNDERING AND COMBATING FINANCING OF TERRORISM POLICY (AML/CFT)

The AML/CFT policy has the following two main objectives :

• Reduce the likelihood of PT Mitra Bisnis Keluarga Ventura (MBK) becoming the tool or the victim of financial crimes

• Improve MBK’s knowledge of its clients and their business using a risk assessment approach dependent on the risk profile of the potential client

The attached AML/CFT pdf file covers the following sections:

1. PRELIMINARY

2. INTRODUCTION

2.1 Objectives of the AML/CFT Policy

2.2 Principles for AML/CFT Policy

3. KNOW YOUR CUSTOMER (KYC)

3.1 Client Identification

Identification documents

3.2 Client Knowledge

Interview With Prospective Client

Client acceptance by MBK

Client acceptance by peers in centre

Case Of Exclusion

Update information

4. MONITORING OF CLIENTS AND OPERATIONS

4.1 Monitoring Of Client Business Activities

4.1 Internal Audits

5. POLITICALLY EXPOSED PERSONS

6. TRACKING AND RECORD KEEPING

6.1 Client records

6.2 Client Document Retention

7. SUSPICIOUS TRANSACTION REPORT

7.1 Suspicion Report Process

7.2 Report content

8. IDENTIFICATION OF MBK PERSONNEL AND TRAINING

8.1 Screening employees

8.2. Staff Training And Responsibilities

9. MANAGEMENT’S RESPONSIBILITIES

10. ANNEX: SUSPICIOUS ACTIVITIES OR TRANSACTIONS

10.1 Main Suspicious Customer Behaviour

10.2 Main Suspicious Transactions

10.3 Suspicious Employees’ Behaviour