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

Policy Statement

CloudTech Group is deeply committed to upholding and enforcing robust anti-money laundering and counter-terrorism financing standards across all facets of our operations. This dedication is rooted in our resolve to comply with all pertinent Australian legal and regulatory frameworks, thereby ensuring our services and operations are not misused for illicit purposes. Our AML/CTF Program serves as the cornerstone of this commitment, embodying our proactive stance against money laundering and terrorism financing activities.

AML/CTF Program

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

- Risk Assessment: Implementing a sophisticated and continuous risk assessment process that scrutinizes 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 effectively counter identified risks.

- Customer Due Diligence: Instituting rigorous due diligence practices to thoroughly vet the identity, background, and intentions of our customers. Enhanced due diligence procedures are applied to relationships and transactions classified as high risk, ensuring a deeper scrutiny to prevent exploitation.

- Regulatory Adherence: CloudTech Group pledges full compliance with the Anti-Money Laundering and Counter-Terrorist Financing Act 2006 (Cth) and other relevant legislation, underpinning our commitment to legal conformity. Our program includes mechanisms to ensure adherence to evolving legal standards and regulatory advisories.

- Training and Capacity Building: Recognising the pivotal role of our workforce in combating money laundering and terrorism financing, we mandate regular, comprehensive training programs. These sessions are designed to enhance the awareness and capabilities of our employees, equipping them with the requisite knowledge to identify, report, and prevent suspicious activities effectively.

- Continuous Monitoring and Reporting: Our AML/CTF Program integrates state-of-the-art monitoring systems for the continuous surveillance of transactions and customer behaviours, facilitating the early detection of potential money laundering or terrorism financing activities. Suspicious transactions are rigorously reviewed and reported in accordance with statutory requirements.

- Record Keeping: Diligent record-keeping practices are observed to maintain detailed documentation of customer identification, transactions, and compliance efforts. These records are preserved to facilitate regulatory inspections and audits, ensuring transparency and accountability.

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.

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.

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.