Neshes Global Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

1. Introduction
Neshes Global, as a multinational organization, is committed to the highest standards of integrity and compliance in preventing money laundering, terrorist financing, and other illicit financial activities. This Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy establishes a robust framework to ensure adherence to global regulatory requirements, including those enforced by the Office of Foreign Assets Control (OFAC), the UK Financial Conduct Authority (FCA), the European Union (EU) sanctions regimes, and other applicable international and local laws. This policy applies to all Neshes Global entities, subsidiaries, employees, contractors, and third-party partners worldwide.

 
2. Purpose
The objectives of this AML/CTF Policy are to:

• Prevent Neshes Global’s operations from being used for money laundering, terrorist financing, or other financial crimes.

• Ensure compliance with OFAC, FCA, EU sanctions, and global AML/CTF regulations, including Financial Action Task Force (FATF) recommendations.

• Protect Neshes Global’s reputation, stakeholders, and clients from financial crime risks.

• Establish a consistent, risk-based approach to identify, assess, and mitigate AML/CTF risks across all jurisdictions.

3. Scope
This policy applies globally to:

• All Neshes Global business units, subsidiaries, and affiliates.

• All employees, contractors, agents, and third-party partners acting on behalf of Neshes Global.

• All client relationships, transactions, products, and services, including cross-border activities.
   

4. Legal and Regulatory Framework
Neshes Global complies with the following regulatory frameworks, as applicable to its operations:

• OFAC Regulations: U.S. sanctions programs, including the Specially Designated Nationals (SDN) List, Sectoral Sanctions Identifications (SSI) List, and other restricted parties lists.

• FCA Regulations: UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), FCA Handbook, and related guidance.

• EU Sanctions: EU Council Regulations on restrictive measures, including asset freezes, financial restrictions, and sectoral sanctions.

• International Standards: FATF recommendations, Basel Committee on Banking Supervision guidelines, and Wolfsberg Group principles.

• Local Laws: Jurisdiction-specific AML/CTF laws in all countries where Neshes Global operates, including but not limited to the U.S. Bank Secrecy Act (BSA), EU Anti-Money Laundering Directives (e.g., 5AMLD, 6AMLD), and local Financial Intelligence Unit (FIU) requirements.
   

5. Governance and Oversight
 
5.1 Board of Directors
The Neshes Global Board of Directors holds ultimate responsibility for:

• Approving the AML/CTF Policy and ensuring its alignment with global regulatory standards.

• Overseeing the establishment of an effective AML/CTF compliance framework.

• Reviewing periodic reports on AML/CTF risks, incidents, and compliance performance.
   

5.2 Global AML/CTF Committee
A Global AML/CTF Committee, chaired by the Money Laundering Reporting Officer (MLRO), is responsible for:

• Developing and updating AML/CTF strategies and policies.

• Monitoring global compliance with AML/CTF regulations.

• Coordinating with regional compliance teams to ensure consistent application of this policy.
   

5.3 Money Laundering Reporting Officer (MLRO)
The MLRO, appointed at the global level, is responsible for:

• Overseeing the implementation and enforcement of this AML/CTF Policy.

• Serving as the primary point of contact for regulatory authorities.

• Receiving, investigating, and reporting suspicious activities to relevant authorities.

• Ensuring adequate resources for AML/CTF compliance across all jurisdictions.
   

6. Risk-Based Approach
Neshes Global adopts a risk-based approach to AML/CTF compliance, tailored to its global operations. Key components include:

• Risk Assessment: Conducting enterprise-wide and jurisdiction-specific risk assessments to identify money laundering, terrorist financing, and sanctions risks based on clients, products, services, delivery channels, and geographic exposure.

• Risk Categorization: Classifying clients and transactions as low, medium, or high risk based on factors such as jurisdiction, client type (e.g., PEPs, corporate entities), and transaction complexity.

• Risk Mitigation: Implementing controls proportionate to identified risks, including enhanced due diligence (EDD), transaction monitoring, and sanctions screening.

• Periodic Review: Updating risk assessments at least annually or upon significant changes in business operations, regulatory requirements, or risk profiles.
   

7. Customer Due Diligence (CDD)
Neshes Global implements robust CDD processes to verify client identities and assess their risk profiles. CDD measures include:
 
7.1 Standard CDD

• Identification and Verification: Collecting and verifying client information, including name, address, date of birth, and government-issued identification (e.g., passport, national ID).

• Beneficial Ownership: Identifying and verifying ultimate beneficial owners (UBOs) for corporate clients, trusts, or other complex structures, ensuring ownership thresholds (e.g., 25% as per FATF) are met.

• Purpose and Nature: Documenting the purpose and intended nature of the business relationship or transaction.

• Source of Funds/Wealth: Verifying the legitimacy of funds or wealth for high-value transactions.
   

7.2 Enhanced Due Diligence (EDD)
EDD is applied to high-risk clients, including:

• Politically Exposed Persons (PEPs), their close associates, or family members.

• Clients from high-risk jurisdictions as defined by FATF, EU, or OFAC.

• Clients involved in complex or high-value transactions.

• Clients with adverse media or reputational risks. EDD measures include:

• Additional verification of identity and source of funds/wealth.

• Senior management approval for establishing or continuing relationships.

• Enhanced transaction monitoring and periodic reviews.
   

7.3 Simplified Due Diligence (SDD)
SDD may be applied to low-risk clients (e.g., regulated financial institutions, government entities) where risk assessments justify reduced measures, in line with regulatory requirements.
 
7.4 Ongoing Monitoring

• Continuously monitoring client activities to ensure consistency with their risk profile, business purpose, and expected transaction patterns.

• Reviewing client risk profiles periodically or upon trigger events (e.g., changes in ownership, sanctions status, or transaction behavior).
   

8. Sanctions Compliance
Neshes Global maintains a rigorous sanctions compliance program aligned with OFAC, FCA, and EU requirements:

• Screening: All clients, counterparties, and transactions are screened against:

  • OFAC’s SDN List, SSI List, and other restricted parties lists.

  • EU Consolidated List of Sanctions.

  • UK Sanctions List (HM Treasury).

  • Other relevant national and international sanctions lists.

• Screening Frequency:

  • At onboarding, during periodic reviews, and upon updates to sanctions lists.

  • Real-time screening for transactions where technologically feasible.

• Escalation and Action: Any sanctions matches are escalated to the MLRO for investigation. Neshes Global prohibits relationships or transactions with sanctioned individuals, entities, or jurisdictions.

• Sanctions Risk Assessment: Incorporating sanctions risks into the enterprise-wide risk assessment, with specific focus on high-risk jurisdictions and sectors.
   

9. Transaction Monitoring
Neshes Global employs advanced transaction monitoring systems to detect and prevent suspicious activities:

• Automated Systems: Using rule-based and AI-driven tools to identify unusual patterns, such as large cash transactions, rapid fund movements, or transactions involving high-risk jurisdictions.

• Red Flags: Monitoring for indicators of money laundering or terrorist financing, including:

  • Transactions with no apparent economic or lawful purpose.

  • Structuring (e.g., breaking transactions into smaller amounts to avoid reporting thresholds).

  • Transactions involving sanctioned jurisdictions or entities.

  • Unexplained wealth or source of funds.

• Manual Review: Flagged transactions are reviewed by the AML Compliance Team, with escalation to the MLRO as needed.

• Cross-Border Transactions: Special attention is given to cross-border transactions to ensure compliance with local and international regulations.
   

10. Suspicious Activity Reporting
Neshes Global promptly reports suspicious activities to the relevant authorities:

• UK: Suspicious Activity Reports (SARs) are filed with the UK National Crime Agency (NCA) in accordance with FCA requirements.

• U.S.: SARs are submitted to the Financial Crimes Enforcement Network (FinCEN) for U.S.-related activities.

• EU: Reports are filed with the relevant Financial Intelligence Unit (FIU) in each EU jurisdiction, per EU AML Directives.

• Other Jurisdictions: Compliance with local FIU reporting requirements where Neshes Global operates.

• Internal Reporting: Employees are required to report suspicious activities to the MLRO immediately, using secure internal channels.
   

11. Record Keeping
Neshes Global maintains comprehensive records in compliance with regulatory requirements:

• Retention Period: Records are retained for a minimum of five years (or longer if required by local laws), including:

  • Client identification and verification documents.

  • Transaction records, including supporting documentation.

  • Sanctions screening results and audit trails.

  • SARs and related correspondence.

• Data Security: Records are stored securely, with access restricted to authorized personnel, in compliance with data protection laws (e.g., GDPR in the EU).
   

12. Training and Awareness
Neshes Global provides comprehensive AML/CTF training to all employees and relevant third parties:

• Content: Training covers:

  • AML/CTF risks and red flags.

  • OFAC, FCA, EU, and local regulatory requirements.

  • Neshes Global’s AML/CTF policies and procedures.

  • Sanctions compliance and reporting obligations.

• Frequency: Training is mandatory at onboarding, annually, and upon significant regulatory or policy updates.

• Tailored Training: Specialized training is provided for high-risk roles (e.g., compliance, client-facing staff, senior management).

• Awareness Campaigns: Regular communications to reinforce AML/CTF awareness and vigilance.
   

13. Third-Party and Vendor Management
Neshes Global ensures that third-party partners and vendors comply with AML/CTF and sanctions requirements:

• Due Diligence: Conducting risk-based due diligence on third parties before onboarding and periodically thereafter.

• Contractual Obligations: Including AML/CTF and sanctions compliance clauses in contracts.

• Monitoring: Ongoing oversight of third-party activities to ensure compliance with this policy.
   

14. Internal Audit and Independent Review
Neshes Global conducts regular internal audits and independent reviews of its AML/CTF program:

• Internal Audit: The Internal Audit Team assesses the effectiveness of AML/CTF controls, reporting findings to the Global AML/CTF Committee and Board.

• Independent Review: An external auditor conducts periodic reviews (at least biennially) to ensure compliance with regulatory requirements and industry best practices.

• Remediation: Any identified deficiencies are addressed promptly, with action plans tracked to completion.
   

15. Cross-Border Compliance
As a multinational organization, Neshes Global ensures consistent AML/CTF compliance across jurisdictions:

• Global Standards: Applying the highest regulatory standards across all operations, even where local requirements are less stringent.

• Local Adaptation: Tailoring procedures to comply with jurisdiction-specific laws while maintaining global consistency.

• Information Sharing: Facilitating secure information sharing between global and regional compliance teams, in compliance with data protection regulations.
   

16. Monitoring and Policy Review
This AML/CTF Policy is reviewed at least annually or upon significant changes, including:

• Updates to OFAC, FCA, EU, or local regulations.

• Changes in Neshes Global’s business operations, risk profile, or geographic footprint.

• Emerging AML/CTF or sanctions risks. The MLRO, in collaboration with the Global AML/CTF Committee, oversees the review process, with final approval by the Board of Directors.
   

17. Consequences of Non-Compliance
Non-compliance with this AML/CTF Policy may result in:

• Disciplinary action, including warnings, suspension, or termination.

• Legal or regulatory penalties for Neshes Global and/or individuals.

• Reputational damage and loss of stakeholder trust. All employees and third parties are accountable for adhering to this policy.
   

18. Whistleblowing and Reporting
Neshes Global encourages reporting of suspected AML/CTF or sanctions violations through:

• Internal Channels: Confidential reporting to the MLRO or Compliance Team via secure platforms.

• Whistleblowing Hotline: An anonymous hotline for reporting concerns, accessible globally.

• Non-Retaliation: Neshes Global prohibits retaliation against individuals reporting in good faith.
   

19. Contact Information
 
For questions, concerns, or to report suspicious activities, contact:
Global Money Laundering Reporting Officer
Email: info@nehsesglobal.com
Address: 1 Canada Square, London E14 5AA, United Kingdom
Phone: +44 (0) 20 1234 5678.
20. Approval and Effective Date
 
This AML/CTF Policy has been approved by the Neshes Global Board of Directors and is effective as of May 29, 2025.
Neshes Global AML/CTF Policy Version 2.0

Last Updated: May 29, 2025
Approved by: Neshes Global Board of Directors