A. Purpose

GESB is committed to conducting its business in accordance with all applicable AML/CTF laws, rules and regulations of the countries and regions where it has operations and/or provides products and services. This AML/CTF Policy applies to all staff; and outlines its procedures for detecting and preventing money laundering and terrorist financing, and sets out the responsibilities of its employees, management and relevant third parties.

B. What is money laundering?

Money laundering is the process whereby individuals seek to conceal the true origin and ownership of the proceeds of a transaction to give the impression that these proceeds originated from a legitimate source.

Money laundering takes many forms, including:

(a) trying to turn money raised through criminal activity into 'clean' money;

(b) handling the benefit of crimes such as theft, fraud and tax evasion;

(c) handling stolen goods;

(d) being directly involved with any criminal property, or facilitating the laundering of criminal property; and

(e) investing the proceeds of crimes.

C. What is terrorist financing?

Terrorist financing is generally the act of providing financial support to terrorism or terrorist organisations enabling them to carry out acts of terrorism. Terrorism financing does not necessarily involve illegitimate funds; in fact, it often uses legitimately obtained income and may involve relatively small amounts of money.

D. Safeguards

1. Customer Due Diligence: GESB will conduct customer due diligence on all customers, suppliers and counterparties, including verifying their identity and assessing the risk of money laundering and terrorist financing. This process will be performed at the beginning of a business relationship and updated regularly.

2. Suspicious Activity Reporting: Employees of GESB and relevant third parties must report any suspicious activity they observe, regardless of its apparent size or importance. Reports should be made to the Chief Legal Officer.

3. Record Keeping: GESB will keep accurate and up-to-date records of all transactions and customer information, in accordance with relevant laws and regulations. These records must be retained for at least five years.

4. Employee Training: All employees will be trained in the detection and prevention of money laundering and terrorist financing, and in their responsibilities under this AML/CTF Policy.

5. Risk Assessment: GESB will regularly assess its money laundering and terrorist financing risks and update this AML/CTF Policy accordingly.

6. Cooperation with Law Enforcement: GESB will cooperate fully with relevant regulators, authorities and law enforcement in any investigation into money laundering or terrorist financing.

7. Review and Monitoring: This AML/CTF Policy will be reviewed and updated regularly to ensure its continued effectiveness in preventing money laundering and terrorist financing.

8. Risk Assessment: The compliance department of GESB must conduct regular risk assessments to identify and assess the money laundering risks associated with GESB ’s products, services, customers, and geographic locations.

E. Obligation To Report

Any employee who has knowledge or a suspicion of (i) a potential money laundering issue; (ii) terrorist financing; or (iii) any failure to report any money laundering issue or terrorist financing by any person, must immediately report the matter to the GESB management before taking any other action.

Each employee must report the matter as soon as he/she is aware. Do not proceed with any transaction where there is any money laundering risk or terrorist financing risk without seeking advice from the GESB management.

F. Failure to Comply or Report 

Failure to:

(a) comply with this AML/CTF Policy; or

(b) report any money laundering or terrorist financing (or suspicion thereof); or

(c) any suspicious activity (which includes circumstances that suggest that a person might be laundering money or any activity that does not fit with the normal course of business);

may lead to criminal, civil and/or regulatory sanctions and penalties for GESB and/or its individual staff who may be subject to internal disciplinary action up to and including dismissal. No staff member should assume that any third parties have reported a suspicion of any money laundering or terrorist financing

Failure to report knowledge or suspicion of money laundering or terrorist financing as soon as reasonably practicable after the information came to any staff member’s attention is an offence; and will be treated as a failure to comply with this AML/CTF Policy.

There are no permitted exceptions to this policy.

G. How to Report a Suspicion

All money laundering and terrorist financing issues must be reported as soon as possible to the GESB management.

Employees should not under any circumstances notify the subject of their concerns or suspicions. Disclosure that someone is the subject of a report or under investigation is a criminal offence in some jurisdictions. Any disclosure is prohibited.