eWealthGlobal Group Limited (“EWG”) is committed to detecting and disrupting financial crime and as such the policies and controls adopted by EWG are designed to ensure that financial crime risks are identified, appropriately mitigated and

managed. These policies and controls, together with this, our anti-financial crime strategy, seek to promote responsible and sustainable growth.

Company details

EWG is a Jersey limited company (registration number: 108106) regulated by the Jersey Financial Services Commission as a Money Service Business.

Summary of the EWG approach to financial crime

EWG recognises the damaging impact financial crime has on our society, communities and customers. We understand our role in deterring, detecting and disrupting it. To this end, EWG is committed to complying with all applicable financial  crime regulations and legislation, including sanctions laws and regulations, which prevent it from being used to facilitate terrorist financing, money laundering, bribery, corruption, and tax evasion.

EWG is committed to conducting business in accordance with the highest standards. We believe that having a comprehensive and effective financial crime framework through policies, as well as appropriate systems and controls to prevent and detect illicit or sanctioned activity is a business imperative and a positive investment that protects EWG from legal, regulatory and reputational risks.

Our financial crime framework determines our approach to collecting and safely storing customer information and explains why we request certain documentation from our customers at the point of opening an account, or thereafter if additional information is needed.

The framework includes policies that apply to all EWG employees, agents, consultants and contractors which have been developed to comply with Jersey legislation and FATF recommendations. Controls maintained by EWG are designed to effectively manage and monitor financial crime risk and ensure that financial crime risk is managed within the EWG’s financial crime risk appetite, hence effectively reducing the risk of EWG being used in connection with financial crime.

EWG is committed to the most effective response to Anti-Money Laundering (“AML”), Counter Terrorist Financing (“CTF”) and Countering Proliferation Financing (“CPF”). Our financial crime risk appetite requires application of robust system and  controls to manage the risks, taking all reasonable steps to manage any residual Money Laundering & Terrorist Financing risks. EWG will not conduct business with individuals or entities that are subject to sanctions regulations, that would violate EWG Policy or that it believes are engaged in illicit activity. EWG has no appetite for establishing or maintaining relationships with customers associated with Money Laundering or Terrorist Financing offences.

EWG’s Board of Directors and ExCo are committed to their responsibilities under Jersey Law and regulations to reduce the extent to which it is possible for EWG to be used for a purpose connected with financial crime, and to protect the  interests of its customers and staff.

EWG Financial Crime (“FC”) Strategy

Our FC Strategy is based around our aspiration to be the core transaction solution providers of choice and to meet and exceed regulatory expectations by having a proactive, informed and dynamic view to managing financial crime risks.

The Strategy and our mission statement to be one of the core transaction solution providers of choice, developing true partnerships with each of our clients and consistently delivering service beyond expectations.

outlines our commitment to disrupt financial crime and to protect our customers

We implement the Strategy through innovation, collaboration and education with the end aim to provide colleagues the right tools to combat financial crime.

We also seek to leverage partnerships with other fintechs and industry bodies, non-governmental organisations, government and other stakeholders where appropriate to help protect the Jersey financial services sector.

AML/CTF/CPF Statement

EWG has established AML, CTF & CPF policies and procedures. These follow a risk-based approach and are subject to annual, and ongoing ad-hoc reviews to combat money laundering, terrorist & proliferation financing risks. These cover the following specifically:

• Comprehensive, risk-based Customer Due Diligence and Know Your Customer.

• Identification of financial crime risks pertaining to our customers, and the adoption of higher risk ratings and

• consequently Enhanced Due Diligence processes when and where appropriate.

• Criteria and measures for Enhanced Due Diligence concerning customers who are judged to present higher financial

• crime risks.

• Establishing and maintaining standards and records for managing information related to Financial Crime.

• Providing a financial crime training and education programme, covering trainings designed to ensure relevant

• employees are aware of their legal obligations relating to deterring, detecting, and disrupting financial crime including

• an annual attestation of their knowledge.

• Complying with relevant FATF recommendations.

EWG has appointed a Money Laundering Reporting Officers (“MLRO”) & Money Laundering Compliance Officer (“MLCO”) in accordance with Jersey its regulatory and criminal law obligations. The MLCO is also the EWG appointed Anti-Bribery and Corruption Officer and is responsible for oversight of the control framework on preventing the facilitation of tax evasion. The MLRO & MLCO report directly to the EWG Board of Directors and deliver an annual report to the Board.

Sanctions Statement

EWG is aligned with local regulatory frameworks and comply with applicable sanctions regimes and we prohibit relationships with customers who are subject to sanctions or who act on behalf of or for the benefit of a government of a comprehensively sanctioned country or would violate our Sanctions Policy. Transactions or undertaking business which is not in compliance with sanctions regulations or would violate EWG Sanctions Policy are also prohibited. This includes any transaction initiated from a jurisdiction which EWG classes as ‘Prohibited’ under our Sanctions Policy. Furthermore, relationships that have, or are proposing to develop business links or derive revenue (or assets) from countries that would breach EWG Sanctions Policy are not accepted or maintained.

Our policies, procedures and processes cover the following sanctions controls:

• Performing business level and customer sanctions risk assessments and implementing controls proportionate to the risks identified.

• Screening customers and payments during onboarding and in an ongoing manner to identify whether potential or current customers are sanctioned targets or whether transactions are prohibited under sanctions regimes or Sanctions Policy. This involves comparing sanctions and terrorist listings from open sources against customer databases and customer (incoming/outgoing) payment instructions.

• Investigating any potential matches identified within clear timeframes and delaying payments as required pending investigation.

• Escalating and reporting true matches to the appropriate sanctions authority.

• Preventing access to accounts (including online and mobile banking) or assets identified as connected to a sanctioned party or jurisdiction, as required.

• Providing training to all relevant staff on different types of sanctions regimes and potential breach channels and providing enhanced training to employees with connections to the US.

• Keeping full records of identified, eliminated or confirmed matches and providing regular information to bank management in relation to sanctions. ▪ Performing assurance testing to ensure that controls are proportionate and appropriate and function well.

We adopt a risk-based approach to charities operating in sanctioned jurisdictions and seek to fully understand sanctions risks associated with any operations or projects.

Anti-Bribery and Corruption (AB&C) Statement

EWG recognise the societal and reputational damage caused by bribery and corruption, and the individual and organisational consequences of failure to prevent bribery. We therefore have no appetite for maintaining relationships with employees and other persons who have engaged in bribery or corruption, or who have attempted to engage in such criminality, whilst acting on our behalf.

We expressly prohibit all forms of bribery and corruption involving our employees and other third parties acting for and on behalf of the bank and require our employees and third-party suppliers and providers to behave ethically and without bribery or corruption at all times when performing any form of service on our behalf.

Our policies are designed to comply with the expectations of applicable anti-bribery legislation in the markets and jurisdictions in which we operate. They apply to all our employees, agency employees, consultants and contractors irrespective of their location, function, grade or standing.

Our policies:

• Explain the relevant legislation and our obligation to prevent bribery by anyone acting for or on behalf of EWG.

• Contain the requirements for identifying, assessing, monitoring and managing bribery and corruption risk. This includes conducting business unit and organisation-wide risk assessments that identify business areas that present higher risks.

• Provide helpful red flag indicators that alert colleagues to bribery or corruption risk.

• Clarify the roles and responsibilities of colleagues across the organisation in relation to anti-bribery and corruption, including senior -level authorisation for transactions, third-party relationships or outsourcing arrangements where appropriate.

• Describe clear channels for escalating and reporting concerns, including through our whistleblowing process.

• Lay down the requirements for mandatory and role-specific training across the organisation, the timely collection and analysis of Management Information, and for assurance testing. Set minimum standards of conduct in relation to anti-bribery and corruption, including clear communication of what is prohibited.

• Require robust controls for risk assessment, due diligence, and approval in relation to activities at more susceptible to bribery and other corruption risks, including charitable activity, corporate sponsorships, employment offers, gifts and hospitality, procurement, customer sourcing, political advocacy, and other interactions with public officials.

• Contain comprehensive requirements for managing the bribery and corruption risks in relationships with Third Party providers of goods and services, including risk assessment, due diligence, contractual provisions, payment controls, and clear communication of EWG’s expectations regarding bribery and corruption, ethical conduct, and channels for reporting concerns.

Finally, as part of our AFC Strategy, we engage with industry and other stakeholders to benchmark the strength of our AB&C framework against the views of expert external working groups, including Transparency International. We seek to  strengthen our framework on an ongoing basis and review our AB&C Policy at least annually. 

Statement on preventing the Facilitation of Tax Evasion

Tax evasion is damaging to the government, businesses and societies in which it occurs. It diverts money and resources from those who need them most, hindering economic and social development. Consequently, we have a zero-tolerance approach to our customers, employees and associated persons facilitating tax evasion whilst acting for or on behalf of EWG. We promote and maintain an ethical business culture, do not tolerate tax evasion in any aspect of our business and to support this our policies are designed to comply with the expectations of applicable anti tax evasion legislation in Jersey.