Anti-Money Laundering (AML) and Fraud Detection Policy Introduction

This Anti-Money Laundering (AML) and Fraud Policy outlines Future Partners’ commitment to preventing the misuse of its operations for money laundering, financing of terrorism, fraud, or other illicit activities. Ensuring compliance with AML regulations and identifying and mitigating fraud risks is critical to safeguarding our business integrity, reputation, and clients. 

Scope 

This policy applies to all employees, contractors, stakeholders, and third parties involved in the activities of Future Partners. It encompasses all operations and jurisdictions where we conduct business. 

Purpose 

The purpose of this policy is to: 

• Prohibit and actively prevent the use of Future Partners’ services for money laundering, fraud, or other financial crimes. 

• Define responsibilities for identifying and mitigating risks related to money laundering and fraud. 

• Establish procedures to ensure compliance with all relevant legal, regulatory, and market standards. 

• Promote an operational culture focused on transparency, accountability, and ethical business conduct. 

Definitions 

• Money laundering: The process by which proceeds derived from criminal activities are disguised as originating from legitimate sources. 

• Fraud: Deliberate deception with the intent to secure unfair or unlawful gain. 

• Suspicious activity: Transactions or behaviour that does not match a customer’s established profile or reasonable expectations and may indicate illicit intentions. 

Policy Principles 

Compliance with legal and regulatory standards  

Future Partners adheres to all applicable AML and fraud-prevention laws, including those set out by: 

• FATF (Financial Action Task Force) recommendations. 

• Any applicable legislation in all jurisdictions where we operate.

  
  

Risk-based approach

A risk-based approach will guide our efforts to identify, assess, and mitigate AML and fraud risks. The company will evaluate client, service, geographic, and operational risks regularly. 

Due diligence measures  

Future Partners ensures robust client due diligence measures are in place, which include: 

• Client identification: Verifying the identity of clients and sub-contractors at the time of contracting (or similar). 

• Enhanced due diligence: Applying additional scrutiny to high-risk clients and transactions. 

• Ongoing monitoring: Continuously reviewing client behaviour and transaction patterns to identify anomalies.   

Suspicious activity reporting (SAR)

Employees, Associates and sub-contractors are required to report any suspicious activity to the Director, who will assess and, if necessary, file a formal Suspicious Activity Report with the relevant authorities. 

Record-keeping  

All records related to client due diligence, transactions, and SARs will be securely maintained for at least five year, or as required by relevant regulations. 

Fraud prevention practices  

Fraud prevention measures include: 

• Real-time transactional monitoring for unusual and fraudulent behaviour. 

• Employee training to identify signs of fraud and report them appropriately. 

• Implementation of technology-based solutions such as fraud detection systems. 

Employee responsibilities

All employees (i.e. the Director) are responsible for: 

• Completing mandatory training on AML and fraud prevention. 

• Reporting any suspected or actual violations of this policy. 

• Ensuring compliance with internal controls and established procedures. 

Third-Party Relationships

Third parties acting on behalf of Future Partners are expected to adhere to this policy and applicable regulations. Contracts with such parties will include specific AML and fraud-prevention clauses. 

Monitoring and review 

• Future Partners will continuously monitor its AML and fraud-prevention framework to ensure effectiveness. 

• This policy will be reviewed annually, or more frequently if required, to adapt to evolving regulatory requirements and industry best practices. 

Reporting and accountability 

• The Director is accountable for the oversight of this policy and ensures its implementation across the organisation. 

• Breaches of this policy will result in disciplinary actions, which may include termination of employment or contractual agreements. 

Training 

All employees will receive regular training on AML regulations, fraud detection, and reporting processes to remain informed of best practices and regulatory developments. 

Zero tolerance 

Future Partners enforces a zero-tolerance approach to money laundering and fraud. Any individual found to be engaging in such activities will face appropriate legal action and internal disciplinary measures. 

Contact for queries 

For queries about this policy or to report suspicious activity, please email Kirsty Burnett, Director, at: Kirsty@futurepartners.cop.nz 

Final Statement 

By following this policy, Future Partners commits to upholding the highest ethical standards, ensuring our operations are not compromised by illegal activities, and fostering trust among clients and stakeholders.