Anti-Money Laundering

Anti-Money Laundering Policy

It is the policy of Collinson’to prohibit and actively pursue the prevention of money
laundering and any activity that facilitates money laundering or the funding of terrorist or
criminal activities.Collinsons’ is committed to AML(anti-money laundering) compliance
in accordance with applicable law and requires its officers , employees and appointed
agents to adhere to these standards in preventing the use of its services for money
laundering purposes.

For the purpose of the policy , money laundering is generally defined as engaging in acts
designed to conceal or disguise the true origins of criminally derived proceeds so that the
unlawful proceeds appear to be derived from legitimate origins or constitute legitimate

Generally , money laundering occurs in three stages.Cash first enters the financial system
at the “placement”stage , where the cash generated from criminal activities is converted
into monetary instruments , such as money orders or travellers cheques , or deposited into
accounts at financial institutions.At the “layering” stage , the funds are transferred or
moved into other accounts or other financial institutions to further separate the money
from its criminal origin.At the “integration” stage , the funds are reintroduced into the
economy and used to purchase legitimate assets or to fund other criminal activities or
legitimate businesses.
Terrorist financing may not involve the proceeds of criminal conduct , but rather an
attempt to conceal the origin or intended use of funds , which will be later used for
criminal purposes.

Customer Identification Process

– Name
– Date-of-birth
– Confirm legitimacy through visit to business or personal premises

Monitoring and Reporting

Transaction based monitoring will occur within the appropriate business units of
Collinsons.Monitoring of specific transactions will include but is not limited to
transactions aggregating NZ$50.000 or more and those with respect to which Collinsons
has a reason to suspect suspicious activity.All reports will documented and retained.
– Validate authenticity of actual Foreign Exchange currency flows in the company or
– Any “Red Flag” investigated thoroughly and verified.

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