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Financial control requires stock exchange companies to prepare a working guide to combat money laundering



The Financial Supervisory Authority has obligated companies listed on the Egyptian Stock Exchange that are licensed to engage in non-banking financial activities to prepare an internal work guide to be approved by its board of directors and to provide the Authority with it upon its approval, which includes the systems and procedures followed to ensure the proper implementation of the rules, controls and procedures related to combating money laundering Financing terrorism, and this guide must include 10 controls, namely:

 

1- Establishing detailed and clear procedures to combat money laundering and terrorist financing operations, and detailed written procedures taking into account the precise definition of duties and responsibilities.

 

2- Mechanisms to verify compliance with the internal regulations established to combat money laundering and terrorist financing operations.

 

3- The requirements to effectively manage risks related to money laundering and terrorist financing, including the human expertise capable of dealing with these risks and the necessary technological infrastructure.

 

4- The internal control systems used in identifying unusual transactions or suspected clients, and placing them under the supervision of the AML / CFT official.

 

5- Procedures for detecting the existence of clients' inclusion in negative lists, procedures to be taken to verify the identity of clients, whether when opening an account or starting a contract, and re-conformity procedures must be followed when updating these lists.

 

6- Systems for classifying clients according to the degree of money laundering and terrorist financing risks and managing these risks, provided that it is updated periodically.

 

7- Procedures to ensure that there is no collusion between the employees of the legal person addressed by the provisions of this decision and its clients.

 

8- Systems that ensure that the internal auditor or audit committees, as the case may be, in coordination with the director responsible for combating money laundering and terrorist financing, examines the systems in place to ensure their efficiency and effectiveness in combating money laundering and terrorist financing operations, and proposing the necessary preventive measures or what they need from Modernization and development.

 

9- The rules for preserving documents and records that the legal persons addressed by the provisions of this decision must keep and determining the methods of keeping them.

 

10- Setting plans and training programs for employees in order to educate them and raise their efficiency with regard to the established rules and regulations regarding combating money laundering and terrorist financing.

 

Financial institutions that have subsidiaries or branches outside the Arab Republic of Egypt must implement programs to combat money laundering and terrorist financing, according to the risks and the volume of work in them, which include the policies, procedures and internal controls received:

 

Establishing an independent audit unit to test the AML / CFT system.

 

Establishing a policy and procedures for exchanging the necessary information for the purposes of due diligence towards clients and managing the risks of money laundering and financing of terrorism between financial institutions and their subsidiaries or their branches, as the case may be.

 

Establishing a mechanism for obtaining information related to customers, accounts and operations from branches or subsidiary companies through the internal auditor, internal auditor and / or anti-money laundering and terrorist financing official when this is necessary for the purposes of combating, provided that these mechanisms include the analysis of all information, reports or processes that It seems unusual, and it is necessary to provide the director responsible for combating money laundering and terrorist financing with the mentioned branches and subsidiaries with this information.

 

This came in Resolution No. 2 of 2021, which was issued by Dr. Muhammad Omran, Chairman of the Financial Supervisory Authority, regarding supervisory controls in the field of combating money laundering and terrorist financing for entities operating in non-banking financial activities.

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