Anti-Money Laundering & Anti-Terrorist Financing Compliance

Learn more about Sigue®’s Anti-Money Laundering & Anti-terrorist Financing Compliance.

Employees are trained in anti-money laundering and anti-terrorist financing upon employment by the Company and on an annual basis thereafter. Further, those employees with direct agent contact, in addition to those employees working in the operations and compliance areas of the institution, receive enhanced anti-money laundering and anti-terrorist financing training on a periodic basis.

Similarly, those employees working as agent relationship managers, compliance agent trainers and internal reviewers, receive additional, specialized, anti-money laundering and anti-terrorist financing training.

Sigue®’s compliance function includes a group of employees dedicated to training and reviewing agent compliance programs.

Agents are trained in anti-money laundering and anti-terrorist financing as a condition of being activated as an agent. Agents also receive periodic enhanced training for the purpose of ensuring their awareness of current issues in the anti-money laundering and anti-terrorist financing environment, as well as to reinforce their knowledge concerning Sigue®’s policies and procedures.

Additionally, agent compliance programs are periodically reviewed and tested using a risk-based approach to assure compliance with Sigue®’s anti-money laundering and anti-terrorist financing policies, as well as applicable laws, rules and regulations.

Sigue® uses a risk-based approach to its anti-money laundering and counter terrorist financing program and develops/maintains and continually enhances controls to detect and prevent money laundering/terrorist financing activity and other crimes. Sigue®’s program consists of layers of controls which include front-end and back-end monitoring designed to interdict or stop transactions, based on internally and externally developed criteria. Additionally, Sigue® conducts extensive monitoring of transactions that facilitates timely and accurate identification and filing of suspicious transaction reports and large cash transaction reports, as required by applicable laws, rules, and regulations and the company’s risk criteria. All reports filed, along with supporting documentation, are maintained for at least five years.

Generally, the monitoring of consumer transaction activity is based on the identification of suspect activity, such as high numbers or amounts of transactions, structuring of transactions, concentration and disbursement of transactions and fund flows to/from high-risk countries.

Agent monitoring addresses activity that presents a likelihood of collusion among agents and/or agents and consumers.

Following identification of unusual activity Sigue® endeavors to:

Conduct investigations pursuant to established procedures to evaluate the entirety of the consumer’s activity and the potential for agent complicity, in addition to formally document the matter.

File appropriate regulatory reports.

Make and implement decisions to maintain or terminate the financial relationship in accord with internal policy or applicable law.

Subsequent to the events of September 11, 2001, denying financial system access to the criminal and terrorist elements in our society has become an even greater concern and importance.

Sigue® recognizes its duty and responsibility as an active participant of the global cooperative against terrorism and criminal financing, and filters millions of transactions each year against relevant sanctions lists in its commitment to meet this obligation.

A function is established for independently reviewing and verifying the compliance of Sigue®’s business units with the business-wide anti-money laundering and anti-terrorist financing policies and underlying procedures.

The AML-ATF Program has been defined as a high priority by Sigue® and is, therefore, subject to annual audits. Sigue® also contracts with an independent outside firm to conduct reviews of its AML and Compliance function on an annual basis.