Good governance is at the centre of our business
Good governance doesn't just make for good business, it is also central to protecting our clients and employees. Money laundering and the illicit financing of criminality and terrorism have been identified as major threats by governments around the world. Alongside this, financial crime and tax evasion undermine international financial systems and distort markets.
At Currency.com we maintain an effective and well-established system of internal controls and robust risk management processes, including pre-trade and post-trade fraud detection systems. Our qualified global compliance teams ensure we comply with all relevant legislation to help us protect our customers and help the fight against money laundering and the financing of terrorism.
Specifically, at Currency.com we:
Self-assessment
Use self-assessment tools to assess our compliance with our internal controls, risk management processes and applicable regulations. The results of the self-assessments are regularly reviewed by Senior Management and the Board of Directors.
Internal Audit
Maintain a professional Internal Audit function that evaluates the adequacy and effectiveness of internal controls, risk management and governance processes; and their level of compliance with applicable rules and regulations. These internal controls are subject to annual assessments to ensure they remain compliant and applicable to new and prevailing rules.
Training & development
We recognise the importance of training and development to keep abreast of prudential requirements and best practices. Our staff attend various training programmes related to their duties including governance and risk management practices, and anti-money laundering.
Mandatory training
In addition, as part of our induction process, we ensure that employees who are responsible for executing and managing financial transactions undergo mandatory anti-money laundering and compliance training. It is also a requirement for employees with fiduciary duties to complete an annual anti-money laundering refresher course.
Acknowledgment
Employees qualified with certificates and professional memberships from organisations including the Association of Certified Anti-Money Laundering Specialists (ACAMS) and the International Compliance Association.
KYC, SOW & SOF
In accordance with Know Your Customer, Source of Wealth and Source of Funds best practice, we verify the identity and residential address of each of our clients. This requirement is reinforced in our Terms & Conditions.
No third-party transactions
We do not receive third party deposits nor make third party withdrawals. All deposits are, where possible, returned to source to prevent facilitating the "layering" of fraudulent proceeds.
Identification technologies
Alongside this, we use innovative document authentication technology and electronic databases to mitigate the risk of identity fraud, including situations involving stolen identity and the use of counterfeit documents. Where necessary, we will use electronic identification methods including carrying out biometric checks and /or requesting "selfie certs" or video calls to verify a client’s identity.
Sanctions hygiene
We also regularly undertake checks for those that may be Sanctioned, Politically Exposed Persons or carrying adverse media. We monitor all transactions to capture and prevent suspicious activity, which also help us to screen clients against sanctioned entities and/or financial institutions.
US Laws
In the US we are registered with the Financial Crimes Enforcement Network (FinCEN) under the registration number 31000177055071. As a condition of our Money Services Businesses (MSB registration) we are mandated to comply with the US Bank Secrecy Act. Alongside this, our banking services in the US are directly regulated by the Bank Secrecy Act and the USA Patriot Act. In line with this legislation, and as a condition for providing us banking services, our banks need to perform periodic audits of our customer transactions.
MSB Registration Status
Regular audit
Finally, we annually engage a leading, independent auditor within the ‘big four’ accounting and auditing firms to evaluate the adequacy and effectiveness of the company’s internal controls, risk management and governance processes, and their level of compliance with applicable rules and regulations.
