BulgeFx is dedicated to preventing money laundering, terrorist financing, and the evasion of sanctions. Adherence to relevant laws and regulations is crucial for maintaining our reputation and public trust. This AML policy outlines the measures we will implement to achieve our organizational goals while ensuring compliance with the regulatory framework for designated non-financial businesses and professions in the Saint Lucia.
Under Article 2 of the Anti-Money Laundering (AML) Law, money laundering is defined as engaging in activities with the knowledge that the funds involved are from criminal acts, including:
Money laundering is an intentional act. Gross negligence, such as failing to report suspected criminal activities to the Financial Intelligence Unit (FIU), may also result in criminal liability.
BulgeFx complies with the following laws and regulations:
The Financial Intelligence Unit (FIU) under the Saint Lucia Central Bank oversees reporting and investigating suspected illicit financial conduct. The Public Prosecution has the authority to initiate legal proceedings for such offenses.
The Regulations do not specify defenses unique to money laundering charges. General criminal defense strategies apply. Criminal proceedings for money laundering cannot be resolved through settlements or plea agreements; cases must be adjudicated in criminal courts.
BulgeFx employs a transaction monitoring system to detect unusual or suspicious transactions. Currently, transactions are manually reviewed using 'Veriff' Identity Verification Service. By 2023, an automated transaction monitoring system will be implemented.
We perform thorough manual reviews of each transaction, which range from $9 to $999. This process is designed to identify any transactions that appear abnormal or suspicious, ensuring compliance with legal standards.
Suspicious transactions are reported to the Financial Services Unit, Ministry of Finance of the Commonwealth of Dominica, through Bank The Kingdom Bank. Records are maintained for at least five years to ensure compliance with legal requirements and facilitate future audits or legal proceedings.
Our dedicated risk management unit conducts manual risk assessments of client profiles, ensuring comprehensive due diligence and risk mitigation in compliance with legal and regulatory frameworks.
Non-compliance with AML standards may result in administrative sanctions, including warnings, fines, business activity restrictions, and actions against board members and senior management. Convictions for money laundering can result in fines from EUR 25,000 to EUR 10 million and imprisonment for up to 10 years.
Annual AML/CFT training includes:
Documentation of training sessions, including attendance records and instructional materials, is maintained. New or amended AML/CFT laws and policies are communicated to relevant staff.
A Designated Compliance Officer oversees the AML/CFT program, ensuring compliance and coordinating day-to-day operations. The Risk Management team performs regular compliance testing.