Anti Money-Laundering and KYC Policy

A. It is the policy of Sky247 to actively prevent the services of the firm being used to facilitate financial crime, money laundering and terrorist financing.
Strict compliance with all applicable regulations will also protect the senior management and staff of the firm, as individuals, from the risks of breaches of the law, regulations, and supervisory requirements, and to preserve the reputation of the Sky247 against the damage that could be caused by being implicated in money laundering and terrorist financing activities.

B. To achieve these objectives, it is the policy of this firm that:
• Every staff member shall meet their personal obligations as appropriate to their role and responsibilities;
• Commercial considerations cannot take precedence over Sky247 anti-money laundering commitment;
• The firm shall appoint a Money Laundering Reporting Officer/Nominated Officer (“MLRO”), and a deputy to cover in their absence, and they shall be afforded every assistance and cooperation by all members of staff in carrying out their duties and responsibilities. The deputy will be the Director Chief Executive Officer (CEO).
Sky247 will strictly comply with all applicable AML/CFT rules and regulations with specific emphasis on:
• A culture of compliance to be adopted and promulgated throughout the firm towards the prevention of financial crime;
• A commitment to ensuring that customer’s identities will be satisfactorily verified at required thresholds;
• A commitment to “knowing its customer” appropriately - both at acceptance and throughout the business relationship - through taking appropriate steps to verify the customer’s identity and monitoring their use Sky247 services;
• A commitment to ensuring that staff are trained and made aware of the law and their obligations under it, and to establishing procedures to implement these requirements; and
• Recognition of the importance of staff promptly reporting their suspicions internally:

C. At the heart of our policies, procedures and controls is the risk-based approach. The risk-based approach means that we focus our resources on the areas of greatest risk.

D. Our policies, procedures and internal controls are designed to ensure compliance with all applicable anti-money laundering and anti-terrorist financing regulations and regulatory guidelines and will be reviewed and updated on a regular basis to ensure appropriate policies, procedures and internal controls are in place to account for both changes in regulations and changes in our business. 

Money Laundering and Terrorism Financing

Money Laundering means:

A. The conversion or transfer of property, knowing that such property is derived from criminal activity or from an act of participation in such activity, for the purpose of concealing or disguising the illicit origin of the property or of assisting any person who is involved in the commission of such an activity to evade the legal consequences of that person's action;

B. The concealment or disguise of the true nature, source, location, disposition, movement, rights with respect to, or ownership of, property, knowing that such property is derived from criminal activity or from an act of participation in such an activity;

C. The acquisition, possession or use of property, knowing, at the time of receipt, that such property was derived from criminal activity or from an act of participation in such an activity;

D. Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counselling the commission of any of the actions referred to in points (A), (B) and (C).

E. Money laundering shall be regarded as such even where the activities which generated the property to be laundered were carried out in the territory of another Member State or in that of a third country.

F. Terrorism financing means the provision or collection of funds, by any means, directly or indirectly, with the intention that they be used or in the knowledge that they are to be used, in full or in part, in order to  carry out any terrorist act.