Company Group
XSpring Digital
7 days ago
Master Policy on Combating Money Laundering and the Financing of Terrorism and Proliferation of Weapons of Mass Destruction
Objectives
XSpring Digital Company Limited (the “Company”) determines to strictly provide cooperation to the public sector and the Global Community to prevent and suppress money laundering, terrorism, and proliferation of weapons of mass destruction financing as per the legislation, including any practices thereby stipulated.
To achieve the aforementioned objectives, the Company hereby stipulates the Master Policy Combating Money Laundering and the Financing of Terrorism and Proliferation of Weapons of Mass Destruction and the minor policies and measures will be arranged to support the compliance with the aforementioned policy, namely, In-house Rules for Risk Assessment and Management concerning Money Laundering and Terrorism and Proliferation of Weapons of Mass Destruction Financing, Customer Acceptance Policy, Risk Management Measure, Employment and Training Policy, Internal Audit Policy Concerning Operating System, and Policy Development and Improvement Policy, with the following principles:
1.1 The Company’s Board of Directors and Executives fully emphasize on prevention and combating of money laundering, terrorism, and proliferation of weapons of mass destruction financing and instruct the employees to strictly comply with the Company’s rules and practices, provisions of laws, and rules of relevant government agencies.
1.2 The Company prescribes that the Risk Management Department is required to supervise and audit the compliance with the Terrorism and Proliferation of Weapons of Mass Destruction Financing Act and liaise with the Anti-Money Laundering Office (AMLO).
1.3 The Company’s Board of Directors and Executives emphasize on stipulation of risk control measures concerning money laundering, terrorism, and proliferation of weapons of mass destruction financing that may arise from utilizing the Company’s products or services.
1.4 The Company’s Board of Directors and Executives provide support and encourage the employees to be sufficiently and consecutively educated on prevention and suppression of money laundering, terrorism, and proliferation of weapons of mass destruction financing in order to comply with the Terrorism and Proliferation of Weapons of Mass Destruction Financing Act with internationally-standardized efficiency.
1.5 The Company’s Board of Directors and Executives prescribe the issuances of orders, rules, and employee handbooks which are consistent with the Policy on Prevention and Suppression of Money Laundering and Terrorism and Proliferation of Weapons of Mass Destruction Financing as per the practices stipulated by the AMLO.
The Company prescribes the In-house Rules for Risk Assessment and Management concerning Money Laundering and Terrorism and Proliferation of Weapons of Mass Destruction Financing by assessing the Departments and Divisions necessarily required to maintain relationships with third parties (customers/partners) by the following steps: risk identification, risk assessment, stipulation of risk mitigation measure, preparation of risk management plan, reporting and following up, risk management performance assessment and, review of risk assessment and management.
The Company prescribes the policy on performance concerning the acceptance of customers or persons engaging in transactions with the Company from time to time consisting the step of requesting the customers to indicate their identities and being identified under the Anti-Money Laundering Act and the Terrorism and Proliferation of Weapons of Mass Destruction Financing Act in order to prove and identify the customers’ identities and to verify the customers’ information by comparing with the black list as stipulated by the applicable laws including stipulating the process for creation or refusal of business relationships or transactions with both domestic and international customers, representatives, partners, and agents who maintain the business relationships with the Company. This will prevent the Company from being utilized as a tool or medium of money laundering or terrorism and proliferation of weapons of mass destruction financing.
3.1 The Company will stipulate the risk management and assessment for the following topics:
(1) In-house risk management for the Company’s products or services or service channels and credit limit;
(2) Risk management for all customers;
(3) Risk management for the inspection of transactions reasonably suspected.
3.2 The Company will stipulate that the storage of data and proof is suitable for the level of risk on money laundering or terrorism and proliferation of weapons of mass destruction financing will be maintained in place and such storage will be in line with the criteria, conditions, and means announced by the AMLO.
3.3 The Company will arrange more suitable and intensive measures on the investigation of the customers to which the extra attention is required or the customers subject to the high risk of money laundering and terrorism and stipulate the sufficient and suitable means to monitor and follow up their transactions.
3.4 The Company will maintain in place the risk management, reviews of information, and facts requiring acquaintance with the customers of audit to regularly acknowledge the relevant facts, particularly high risk customers. If the risk of money laundering or terrorism and proliferation of weapons of mass destruction financing is discovered, the Company will consider rejection or cessation of building the relationship or restriction of the transaction to be conducted with the customers and reporting the same as the transaction reasonably suspected to the AMLO.
3.5 The Company will stipulate that the transaction audit measure to learn the facts concerning the customers by the risk arising from the relationship must be implemented and the accounted movement will be consecutively followed up.
The Company will stipulate the management measure for the risk that may be related to money laundering or terrorism and proliferation of weapons of mass destruction financing which is suitable for the risk levels of the customers, regardless of new or existing customers, according to international standards in order to ensure that such measure is capable of preventing or mitigating the risk on utilizing the Company as a channel or medium of money laundering and terrorism and proliferation of weapons of mass destruction financing.
The Company will arrange the employment rules by prescribing the qualifications of the employees that their records must be clean from the crime against the Anti-Money Laundering Act and the Terrorism and Proliferation of Weapons of Mass Destruction Financing Act. Additionally, the Company’s employees and personnel are instructed to regularly participate in orientation and training concerning compliance with the aforementioned Acts to enable them to accurately perform their duties.
The Company delegates the Compliance Department, an independent Department performing the duties of supervision and audit the compliance with this Policy by planning the supervision and audit of the relevant Departments and Divisions to be consistent with the rules, criteria, and measure on prevention and suppression of money laundering, terrorism, and proliferation of weapons of mass destruction financing stipulated by the Company.
The Company delegates the Risk Management Department to clearly prescribe the types of transactions and means and steps of transaction reporting under the criteria stipulated by the AMLO to liaise with the AMLO in regard to the relevant transaction reporting.
Regarding the AMLO rules, the Company has never shared information with others; however, the Company shall stipulate the detailed operational measures so as to support the sharing.
The Company will arrange the risk identification and assessment including the stipulation of management and mitigation measures on money laundering and terrorism and proliferation of weapons of mass destruction financing risk that may arise prior to the Company’s operations as follows:
(1) Development of new products, services, business models, or channels, or mechanisms for services;
(2) Application of cutting-edge or developing technologies to the existing and new products and services concerning the launching of products and services.
In this regard, the Company shall perform actions under the criteria promulgated by the AMLO.
The Company will stipulate the additional policies and measures to support compliance with the Anti-Money Laundering Act and the Terrorism and Proliferation of Weapons of Mass Destruction Financing Act in order to ensure that the Company has comprehensively and sufficiently stipulated various policies and measures to prevent being utilized as a channel for money laundering and terrorism and proliferation of weapons of mass destruction financing.
The Company will arrange stipulation of policy development, review, and improvement plan including employee handbooks relevant to preventive and suppressive measures on money laundering and terrorism and proliferation of weapons of mass destruction financing by delegating the relevant sub-working group to review the relevant master and/or minor policies at least one time per annum and propose the recommendation to the Company’s Board of Directors for consideration.
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