CloudTech Group Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Policy
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Policy Statement

CloudTech Group is committed to upholding and enforcing robust anti-money laundering and counter-terrorism financing standards across all facets of our operations. Our AML/CTF Policy serves as the cornerstone of this commitment, embodying our stance against money laundering and terrorism financing activities.

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AML/CTF Policy

Our AML/CTF Policy encapsulates a holistic and dynamic approach towards identifying, mitigating, and managing the risks associated with money laundering and terrorism financing. Key components of our Policy include:

  • Risk Assessment: Implementing a continuous risk assessment process that scrutinises various elements, including but not limited to, customer profiles, the nature and complexity of products and services offered, delivery channels, and geographic locations of operation. This process ensures the tailoring of our control measures to mitigate identified risks.
  • Customer Due Diligence: Instituting due diligence practices to vet the identity, background, and intentions of our customers including beneficial owners. Enhanced due diligence procedures are applied to customers, transactions and jurisdictions classified as higher risk.
  • Regulatory Adherence: CloudTech Group complies with the relevant AML/CTF legislations in Australia.
  • Continuous Monitoring and Reporting: Our AML/CTF Policy integrates both automatic and manual monitoring systems for continuous surveillance of transactions and customer behaviours, facilitating the early detection of potential money laundering or terrorism financing activities. Suspicious transactions are reviewed and reported in accordance with statutory requirements.
  • Record Keeping: Record-keeping practices are observed in accordance with record-keeping obligations to maintain documentation of customer identification, transactions, and compliance efforts. These records are preserved to facilitate regulatory inspections and audits, ensuring transparency and accountability.

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Governance and Compliance

  • Designated Compliance Officer: The Money Laundering Reporting Officer (MLRO) is responsible for overseeing the implementation of our AML/CTF Program and ensuring compliance with all regulatory obligations.
  • Independent Review: The effectiveness of our AML/CTF Program is regularly evaluated through independent audits, ensuring its alignment with legal requirements and industry best practices.
  • Board Oversight: The ultimate responsibility for the AML/CTF Program rests with our Board of Directors, which, along with senior management, ensures the allocation of sufficient resources and fosters a culture of compliance throughout the organisation.

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Policy Breaches

Employees are required to report any suspected breaches of this Policy through the appropriate channels, including direct reports to managers or Compliance. Policy breaches will be investigated thoroughly, with confirmed violations subject to disciplinary action, up to and including termination of employment.

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Policy Oversight and Training

The responsibility for the oversight of this Policy rests with Compliance who report to the Risk and Compliance Committee. Management is tasked with ensuring all employees are educated about this Policy and its implications. Regular training sessions will be conducted to ensure ongoing awareness and compliance.