Establishing the framework by which Intraday Group Ltd prevents, detects, and reports money laundering, terrorist financing, fraud, corruption, and other financial crimes.
Establishing the framework for preventing, detecting, and reporting financial crimes.
This Anti-Money Laundering (AML) & Compliance Policy establishes the framework by which Intraday Group Ltd ("the Company") prevents, detects, and reports money laundering, terrorist financing, fraud, corruption, and other financial crimes.
The Company is committed to full compliance with applicable laws and regulations across all jurisdictions in which it operates.
Financial Action Task Force international standards
AMLD6 and subsequent regulations
Bank Secrecy Act requirements
Applicable regulatory framework
Intraday Group Ltd is a private investment and asset management firm providing comprehensive financial services to discerning clients worldwide.
Portfolio management and strategic investment advisory
Strategic advisory and comprehensive documentation verification
Regulatory compliance documentation and analysis
Comprehensive risk assessment and fraud detection
Due to its business model, the Company faces elevated risk exposure in:
Understanding our business model and the inherent risks in our operations.
Essential terminology used throughout this policy
Concealment of illicit funds to make them appear legitimate through layering and integration processes.
Funding of terrorist activities, whether for ideological, religious, or political purposes.
Any individual or entity engaging the Company for financial services or advisory.
Natural person(s) who ultimately owns or controls a client entity (≥25% ownership).
Politically Exposed Person - individuals holding prominent public functions.
Know Your Customer - verification procedures to identify and understand clients.
Clear accountability structure for AML compliance across all levels
Ultimate oversight responsibility
Money Laundering Reporting Officer
The Company appoints a dedicated MLRO responsible for:
Led by Head of Risk & Compliance
The Company adopts a risk-based approach, applying enhanced controls where risks are higher
Standard procedures apply
Enhanced monitoring required
Enhanced due diligence mandatory
Comprehensive verification procedures before client onboarding
All clients must complete verification before engagement
Before onboarding any client, the Company must obtain:
Complete legal identification
Date of incorporation for entities
Proof of residence or registration
Passport, registration certificates
Documentation of legitimate origin
Ultimate beneficial owners holding ≥25% shareholding or control
Verify ownership structure and control mechanisms
Additional verification measures for high-risk clients and situations
Domestic or foreign PEPs and their associates
Transactions involving high-risk countries
Multi-layered ownership and trusts
Complex cross-border movements
Independent verification of legitimate origins
Comprehensive negative news checks
Board or executive committee sign-off
Enhanced ongoing surveillance
Zero tolerance for engagement with sanctioned entities or illicit activities
All clients and transactions must be screened against:
United Nations Security Council
Office of Foreign Assets Control
European Union restrictive measures
His Majesty's Treasury
Screening Timing: Conducted at onboarding AND on an ongoing basis
The Company implements controls to identify suspicious patterns and behaviors
Deviations from normal activity
Activity inconsistent with client profile
Quick layering through accounts
Breaking transactions to avoid thresholds
Clear procedures for reporting and escalating concerns
Employees must immediately report suspicious activity to the MLRO through designated channels
The MLRO will file Suspicious Activity Reports (SARs) with relevant authorities where required
Documentation retention requirements
Minimum mandatory retention
Staff education requirements
All employees must complete AML training covering essential topics
Understanding regulatory requirements
Identifying warning signs
How to escalate concerns
At Onboarding
Annually
All client data is handled in compliance with applicable data protection regulations
The Company conducts due diligence on all business partners and intermediaries
Regular reviews and continuous improvement of compliance processes
Periodic review of AML processes and controls
External assessment of compliance framework
Ongoing enhancement of controls and procedures
Zero tolerance policy aligned with global best practices and ESG governance principles
Prohibited without exception
No inducements or improper benefits
Must be disclosed and managed
ESG Alignment: This policy is aligned with global best practices and ESG governance principles
Failure to comply with this policy may result in serious consequences
This policy is subject to regular review and updates
Scheduled yearly review
Updated laws or guidance
Incident-triggered reviews
All employees and relevant stakeholders must acknowledge and comply with this AML & Compliance Policy.
By adhering to this policy, we demonstrate our commitment to combating financial crime and maintaining the highest standards of integrity in all our business operations.
Supporting documents recommended for the full policy version
Standardized format for evaluating client and transaction risks
Comprehensive verification requirements for new clients
Standardized format for internal SAR documentation
Common warning signs of potential money laundering
Detailed process for watchlist and sanctions checks
Forms, templates, and operational procedures