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AML Policy and KYC Policy

Money laundering is the movement and disguise of cash or other assets generated from illegal activities through legitimate financial institutions or businesses so as to conceal the source of the funds or make it appear that the source of the funds is, in fact, legitimate. Both international and Biwako Partners LTD regulations require Biwako Partners LTD to implement effective internal procedures ensuring that anti-fraud, anti-money laundering, and anti-terrorist financing measures are in place.


1.The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (SI 2017 No. 692)

2.The Proceeds of Crime Act 2002 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2015)

3.The Money Laundering Regulations 2007 (SI 2007 No. 2157)

4.The Terrorism Act 2000 (as amended by the Anti-Terrorism, Crime and Security Act 2001, the Terrorism Act 2006 and the Terrorism Act 2000 and Proceeds of Crime Act 2002 (Amendment) Regulations 2007).

The Money Laundering Regulations 2017 transposes the European Union’s 4th Anti Money Laundering Directive (the ‘4th AML Directive’) which sets out a risk based approach which is tailor made to the business being carried out by Biwako Partners LTD; and The Joint Money Laundering Steering Group (JMLSG) Guidance for the Financial Sector on the prevention of money laundering/combating terrorist financing.

One of the ways which Biwako Partners LTD ensures that it is not an unknowing accomplice to money launderers is to carry out customer due diligence (hereinafter referred

to as “CDD”) at the point of on-boarding new customers, as well as on an ongoing basis. Our KYC policy and CDD procedure aims first and foremost at identifying the individuals and persons with whom Biwako Partners LTD is doing business, and which companies and the persons behind them are sending and receiving funds. This is ensured by establishing to the best extent possible:

  • that clients have valid and adequate proof of identification, proof of residence;
  • that Biwako Partners LTD is able to maintain records of identification information;
  • that Biwako Partners LTD is able to determine that clients are not known or suspected terrorists or criminals by checking their names against lists of known or suspected terrorists and criminals;
  • closely monitoring clients’ money transactions.
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