AML GUIDELINES
Anti-Money Laundering (AML) Policy
This Anti-Money Laundering (AML) Policy outlines the internal policies, procedures, and controls established by HELLO Holdings to prevent the use of its services for money laundering, terrorist financing, and other financial crimes. HELLO Holdings is committed to full compliance with the Anti-Money Laundering Regulations, 2008 and other applicable legislation and guidance issued by the Financial Investigation Agency (FIA) of the British Virgin Islands.
Application
This policy applies to all employees, officers, agents, and contractors of HELLO Holdings, and to all operations, products, services, and customer interactions, both in the British Virgin Islands and globally.
HELLO Holdings has designated Sander Gortjes as the AML Compliance Officer (AMLCO). Responsibilities include:
Designing and maintaining the AML compliance program
Conducting risk assessments
Overseeing due diligence procedures
Filing Suspicious Activity Reports (SARs)
Providing AML training to staff
HELLO Holdings will apply Customer Due Diligence (CDD) measures to all clients, including:
a. Standard CDD
Verification of identity (full name, date of birth, nationality)
Verification of address
Collection of purpose and nature of the business relationship
b. Enhanced Due Diligence (EDD)
Required when:
A client is a Politically Exposed Person (PEP)
The business relationship or transaction presents a higher risk
The client is from a high-risk jurisdiction
Transactions and business relationships will be monitored for:
Consistency with known customer profiles
Unusual patterns or high-risk activity
Changes in customer behavior or beneficial ownership
All unusual activity will be reported to the AMLCO for further review.
HELLO Holdings will maintain records of:
Customer identification and verification
Transactions and account activity
Internal and external reports made
All records will be kept for at least five (5) years from the end of the business relationship, in accordance with BVI law (over a certain threshold).
All employees are required to report suspicious transactions to the AMLCO immediately. The AMLCO will assess the report and, where necessary, submit a Suspicious Activity Report (SAR) to the Financial Investigation Agency (FIA) of the British Virgin Islands.
All relevant staff will receive AML training:
At the time of hiring
On an annual basis
Upon any major regulatory or internal policy change
Training will include recognizing red flags, understanding reporting obligations, and compliance procedures.
HELLO Holdings conducts an annual risk assessment to identify and evaluate:
Customer risk
Geographic exposure
Delivery channels and transaction types
Emerging threats or typologies
The AML program is adjusted based on the results of this assessment.
Enhanced Due Diligence (EDD) Policy
Our objective is to ensure full compliance with Anti-Money Laundering (AML) regulations and protect the company and investors from being used for money laundering or financing of terrorism.
Application
This policy applies to all high-risk customers, including:
Politically Exposed Persons (PEPs)
Customers from high-risk jurisdictions
Customers involved in unusual or suspicious activities
Customers with complex ownership structures
Customers identified during AML screening as requiring further investigation.
Requirement
EDD will be applied when the following risk factors are identified:
The customer is a PEP, their family members, or close associates.
The customer is located in or has transactions linked to a high-risk jurisdiction.
The customer’s activities or transactions appear unusual, large, or inconsistent with their stated business or personal profile.
The customer has a complex or opaque ownership structure, such as shell companies or trusts.
The customer’s name or business is flagged in sanction lists, adverse media, or linked to criminal activity.
Procedure
a. Client Information Verification
For all high-risk clients, the following steps must be taken:
Full legal name, date of birth, and nationality for individuals, or legal entity details for businesses.
Verification of the client’s residential address or business location.
Valid identification documents (government-issued ID, passport, company registration).
Liveness check (selfie or video verification).
Enhanced KYC forms to capture additional background information.
b. Source of Funds (SoF) Verification
Obtain and verify the source of funds used for the current transaction or business relationship.
Supporting documents may include:
Recent bank statements or proof of income.
Invoices or contracts for business transactions.
Loan agreements, asset sales, or other financial documents.
c. Source of Wealth (SoW) Verification
Obtain and verify the source of the client's total wealth.
Supporting documents may include:
Business ownership and revenue records.
Tax returns or audited financial statements.
Evidence of real estate holdings, investments, or inheritance.
Monitoring and Review
High-risk customers will be monitored continuously, with special attention to:
Unusual or large transactions that deviate from the expected pattern.
Inconsistent information or activities.
Changes in ownership or business structure.
Customer information will be reviewed periodically (approx. 6 to 12 months) to ensure it remains accurate and up-to-date.
Approval and Escalation Process
Any high-risk customer that requires EDD must be reviewed and signed off by the AML Compliance Officer (AMLCO).
If necessary, the review will be escalated to senior management for further assessment and decision-making.
For clients with ongoing high risk, the company may choose to terminate the relationship or impose restrictions.
Recordkeeping and Documentation
All documents collected as part of the EDD process (ID verification, source of funds, source of wealth, approval records) must be securely stored for a minimum of 5 years.
Detailed records of the EDD process and any rationale for risk assessments should be maintained.
Files should be tagged for periodic review to ensure compliance with ongoing monitoring requirements.
Training and Awareness
All employees involved in customer onboarding, compliance, and monitoring must be trained on the following:
Identifying and understanding high-risk clients and transactions.
The EDD process and required documentation.
Recognizing and reporting suspicious activity.
Any changes to this EDD Policy and AML regulations.
Policy Review
This policy will be reviewed and updated annually, or more frequently if necessary, to ensure:
Compliance with local and international AML regulations.
Reflection of changes in the company’s risk profile or customer base.
Implementation of any new technologies or processes for client screening.
Ongoing Monitoring Policy
This Ongoing Monitoring Policy outlines the procedures HELLO Holdings will follow to continuously monitor its existing customers and their transactions. This ensures that the company remains compliant with applicable Anti-Money Laundering (AML) laws and regulations of the British Virgin Islands, and international best practices, including FATF recommendations.
Application
This policy applies to:
All customers of HELLO Holdings
All products and services offered
All relevant staff involved in customer due diligence, compliance, and transaction processing
Objectives
The objectives of ongoing monitoring are to:
Detect suspicious activity
Identify changes in customer behavior or risk profile
Ensure customer information remains current and accurate
Maintain a risk-based approach to compliance
Risk-Based Approach
HELLO Holdings applies a risk-based approach to ongoing monitoring:
High risk
Quarterly (or continously if needed)
Medium risk
6-12 months (as needed)
Low risk
Annually (if needed)
Monitoring Activities
5.1. Transaction Monitoring
Monitor transactions to ensure they align with the customer’s expected behavior, profile, and source of funds.
Look for:
Unusually large or frequent transactions
Transactions to or from high-risk jurisdictions
Rapid movement of funds
Use of shell companies or complex structures
5.2. Screening
Re-screen customers periodically against:
Sanction lists (OFAC, UN, EU)
Politically Exposed Persons (PEP) lists
Adverse media databases
Screening should be automated where possible, and performed at regular intervals or upon significant changes.
5.3. Customer Information Review
Regularly update:
Identity documents
Address or contact details
Ownership and control structures (for corporate clients)
Source of Funds (SoF) and Source of Wealth (SoW) information (especially for high-risk clients)
Escalation and Reporting
If suspicious activity is detected:
Staff must immediately report it to the AML Compliance Officer (AMLCO).
A decision will be made as to whether a Suspicious Activity Report (SAR) should be filed with the BVI Financial Investigation Agency (FIA).
Further action may include:
Freezing the account or suspending the relationship
Conducting an internal investigation
Escalating to senior management
Use of Technology
HELLO Holdings may use automated transaction monitoring and screening systems to:
Identify abnormal patterns
Flag PEPs and sanctioned individuals or entities
Maintain an audit trail for all monitoring and compliance decisions
Training and Staff Awareness
All employees involved in client-facing, compliance, and transaction roles will receive:
Initial and annual AML/ongoing monitoring training
Scenario-based workshops for identifying suspicious behavior
Updates when regulations or internal policies change
Recordkeeping
All monitoring activities, alerts, actions taken, and SARs (if filed) must be documented and stored securely for a minimum of 5 years.
Audit logs must be maintained for all automated monitoring systems used.
Policy Review
This policy will be reviewed:
At least annually
After any significant regulatory or operational change
Upon request by regulators or auditors
Transaction Monitoring Policy
This policy outlines HELLO Holdings’ approach to Transaction Monitoring (TM) as required under the AML regulations of the British Virgin Islands and in line with FATF recommendations. Its purpose is to ensure transactions conducted through the company are consistent with the customer's profile and to detect suspicious or potentially illegal activity.
Application
This policy applies to:
All customers and counterparties
All transaction types (incoming/outgoing, fiat/crypto, cross-border/local)
All products and services offered
All staff involved in transaction processing or monitoring
Objectives
The goals of this policy are to:
Identify unusual or suspicious transactions
Prevent money laundering, terrorist financing, and other financial crimes
Ensure the effectiveness of HELLO Holdings’ risk-based AML framework
Escalate and report concerns internally and to the BVI Financial Investigation Agency (FIA) when required
Risk-Based Monitoring
Transaction monitoring is conducted using a risk-based approach:
High risk
Real-time (as close to)
Medium risk
Monthly manual
Low risk
Automated batch
Monitoring Triggers and Red Flags
Large or frequent transfers inconsistent with customer profile
Sudden increase in transaction size or volume
Unexplained cross-border transactions
Use of high-risk jurisdictions
Structuring
Use of third-party accounts
Round-dollar or round-trip transactions
HELLO Holdings maintains an internal Red Flag Indicators List to support staff in identifying suspicious behavior.
Monitoring Methods
HELLO Holdings will use the following tools and techniques:
Automated rules-based monitoring system for transaction pattern recognition
Manual reviews of flagged alerts or high-risk client activity
Real-time screening for certain high-risk customers (where applicable)
PEP, sanctions, and adverse media screening during or before execution
Investigation and Escalation Process
If a transaction is flagged:
The Compliance Analyst reviews the transaction and related customer data.
If the alert cannot be reasonably explained:
It is escalated to the AML Compliance Officer (AMLCO).
The AMLCO determines:
Whether to request more information from the customer.
Whether to file a Suspicious Activity Report (SAR) with the BVI FIA.
Whether to freeze the transaction or terminate the customer relationship (if necessary).
Reporting Suspicious Activity
SARs will be filed in accordance with the BVI Proceeds of Criminal Conduct Act (POCCA).
SARs are confidential and must only be shared with relevant authorities and internal compliance staff.
Tipping-off is strictly prohibited.
Recordkeeping
HELLO Holdings will retain:
All alerts, investigations, actions taken, and SAR filings
Transaction data and monitoring logs
Records for at least 5 years in a secure, tamper-proof format
Training
All relevant employees must receive transaction monitoring training at onboarding and annually.
Training must cover:
Red flag indicators
Use of monitoring tools
Escalation procedures
Legal responsibilities, including SAR filing
Review and Updates
This policy will be reviewed:
Annually
Upon major regulatory changes or operational shifts
After feedback from regulators or internal audit
Governance and Oversight
The AML Compliance Officer is responsible for:
Policy implementation and oversight
Ensuring transaction monitoring systems are effective
Ensuring appropriate staffing, training, and escalation channels
Anti-fraud Policy
The purpose of this Anti-Fraud Policy is to outline HELLO Holdings’ commitment to preventing, detecting, and responding to all forms of fraud and fraudulent behavior. Fraud threatens the financial stability, integrity, and reputation of the company and its stakeholders.
Application
This policy applies to:
All employees, contractors, officers, and directors
Third parties including vendors, customers, and business partners
All jurisdictions where HELLO Holdings operates
Definition of Fraud
Fraud is defined as any intentional act or omission designed to deceive others, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. This includes but is not limited to:
Misappropriation of assets
Falsification of records or documents
Identity theft or impersonation
Insider trading
Bribery and corruption
False accounting or expense reporting
Money laundering or aiding illicit transactions
Zero Tolerance Statement
HELLO Holdings maintains a zero tolerance approach to fraud. Any employee or third party found to be engaging in fraudulent activity will be subject to disciplinary action, which may include termination of employment, legal action, and reporting to authorities.
Roles and Responsibilities
5.1. All Employees
Report suspected fraud immediately
Cooperate with internal and external investigations
Comply with all relevant controls and policies
5.2. Management
Promote an ethical culture
Implement fraud prevention controls in their areas of responsibility
5.3. Compliance / AML Officer
Maintain and review this policy
Investigate fraud reports and escalate to senior management or law enforcement
File Suspicious Activity Reports (SARs) when required
Fraud Prevention Measures
HELLO Holdings shall implement the following to prevent fraud:
Know Your Customer (KYC) and customer due diligence
Background checks during hiring and onboarding
Segregation of duties and access controls
Transaction monitoring systems (for both fiat and crypto)
Vendor due diligence and contract audits
Whistleblower mechanism for anonymous reporting
Fraud Detection
Fraud may be detected through:
Internal audits and reviews
Red flag indicators in financial or behavioral activity
Customer or staff complaints
Automated monitoring alerts (e.g., suspicious transaction patterns)
Anonymous whistleblowing reports
Reporting and Investigation Process
Report: Any suspicion of fraud must be reported to the AMLCO or via the whistleblowing channel.
Review: The AMLCO will perform an initial risk assessment.
Investigation: If warranted, a formal investigation will be conducted discreetly.
Outcome: Actions may include disciplinary sanctions, legal escalation, or SAR filing with the BVI Financial Investigation Agency.
Confidentiality: All investigations will be kept confidential to the extent possible.
Protection: Whistleblowers will be protected from retaliation.
Training and Awareness
All staff will be provided with training on:
How to recognize fraud
How to report suspicious activity
The consequences of committing or ignoring fraud
Training is mandatory at onboarding and annually thereafter.
Recordkeeping
All reports, investigations, and actions taken will be documented and securely stored for at least 5 years in accordance with regulatory obligations.
Policy Review
This policy will be reviewed annually or upon:
Material regulatory changes
Fraud incident findings
Audit or regulator recommendations
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