Titoff Realty Ltd. recognizes the importance of ensuring suitable procedures are in place to properly evaluate its customers. A crucial aspect of these procedures is adequate due diligence with regards to new and existing customers. Wide-ranging Know Your Customer (KYC) procedures have particular relevance to the safety and security of Titoff Realty Ltd. In addition to guarding the Company’s reputation, they also decrease the likelihood that the Company will become a victim of financial crime and consequently suffer damage to its reputation. We understand that a lack of KYC procedures can subject the Company to serious customer and counter-party risks, including potential harm to its reputation, operations, and legal standing. In order to foster high professional and ethical standards, we have instituted sufficient policies, practices, and procedures that inhibit the Company from being taken advantage of by criminal parties.
Our KYC program incorporates the following key elements:
– a policy of customer acceptance
– customer identification
– ongoing monitoring of high-risk accounts
– risk management
Our process includes several safeguards to determine which account activity does not align with standard requests for that level of customer account. We not only determine customer identity; we also closely monitor account activity.
Customer Acceptance Policy
Titoff Realty Ltd. has developed clear-cut policies and procedures of customer acceptance. We have established guidelines about what types of customers are most likely to pose a higher-thanaverage risk to the Company. When reviewing a new international business corporation (IBC), we also consider such factors as customer background, country of origin, business activities, and other risk indicators like the level or profile of their position.
In particular, we perform due diligence on high net worth customers who have been labeled higher risk, because the source of their funds is less than clear.. The Company seeks to strike a balance between security and customer access. We do not want our customer acceptance guidelines to be so stringent that they decrease public access to our services.
Here at Titoff Realty Ltd., we realize that customer identification is essential to maintaining KYC standards. For this reason, we have instituted a means of identifying new customers. Until the new customer’s identity has been verified to our satisfaction, we do not provide potential customers any service. We also conduct periodic examinations of our existing records, in order to guarantee that they are current, and keep copies of customer identification papers for at least five years after the opening of an account. Our standards of what customer identification records we keep and for how long are clearly delineated. This clarity is essential, not only because it enables the Company to monitor its customer relationships and ongoing business, but also because it provides necessary information in the event of any legal disputes or financial investigations related to possible criminal prosecution.
Titoff Realty Ltd. obtains all needed information to satisfactorily verify the identity of each new customer. When verification issues develop with a registered IBC that cannot be resolved, we normally close the account and notify the client that we have resigned as their registered agent. In our evaluation of future customers, we take into account whether or not the customer account was previously transferred. Of course customers are entitled to transfer their business from one agent to another; yet, this might be a sign that a previous registered agent had flagged an IBC out of a concern for alleged illegal activities. If we have any reason to believe that an applicant was denied service by another registered agent, we increase our diligence procedures when assessing the customer.
We never approve the incorporation of an IBC or conduct any business with a customer who either demands anonymity or uses a fictitious name.
Ongoing Monitoring of High Risk Accounts
A crucial aspect of Titoff Realty KYC procedures is ongoing monitoring. In order to effectively control and reduce our risk, we scrutinize our clients’ activity and evaluate it based on our knowledge of what constitutes acceptable and routine business behavior. A firm understanding of such patterns means that, when required, we are successfully able to report questionable activity to the relevant authorities.
The Role of Director and KYC Supervisor
The responsibility of the director and KYC supervisor is not only to determine the basic guidelines for Titoff Realty but also to oversee the Company’s application of sound KYC procedures and its ongoing maintenance of high professional and ethical standards. The role of the supervisor is to guarantee that suitable internal controls are in place and that the Company complies with supervisory and regulatory rules. The process of supervision entails both a review of policies and procedures and also an evaluation of customer files. The supervisor’s duties extend beyond the direct protection of the Company’s safety through the maintenance of high KYC standards to the protection of the integrity of the whole offshore industry in Belize.
In order to prevent the Company from being taken advantage of by criminal parties, the supervisor will ensure that they have sufficient procedures and practices in place that encourage high ethical and professional standards.. This includes the prevention and detection of fraud or illegal activity. If suspected activities are found, the supervisor is responsible for reporting these matters to the appropriate authorities.
It is up to the supervisor to determine that the Company has documented and enforced policies for customer identification and for those engaged on their behalf in the anti-money-laundering program. Clear rules exist regarding what client identification records must be retained and for how long. The supervisor determines that the Company has formal procedures to recognize potentially suspicious customers. The supervisor is explicitly responsible for confirming that the Company’s policies and procedures are, at a minimum, in agreement with the requirements of local anti-money laundering statutes and regulations.
In addition to guaranteeing the clarity of Company procedures, the supervisor must ensure that these guidelines are properly communicated to all personnel. Staff should be trained in how to report suspicious customers to the dedicated senior officer responsible for anti-money laundering compliance. In order to protect the safety, soundness and reputation of the Company, personnel should not only report any suspicious activities and incidents of potential fraud to the relevant criminal authorities but also to the supervisor.