This policy applies to 
All Employees in Lilion Transfer subsidiaries as well as partners providing service.

All Non-Executive Directors up to and including the Chairman.

Policy objectives

• To ensure that Lilion Transfer comply with international and relevant domestic anti-money laundering (AML) and counter terrorist funding (CTF) practices in all jurisdictions in which it operates. This includes compliance with both the specific requirements and the spirit of all relevant laws and regulations.
• To protect Lilion Transfer and its employees contracted staff and third party agents from inadvertently committing money laundering and terrorist financing offences or from failure in operational controls.
• To avoid reputational damage to Lilion Transfer by having consistent controls in place that deter abuse of Lilion Transfer services by money launderers and those involved in financing terrorism.

The policy 
It is the policy of the Board of Lilion Group to ensure that appropriate controls are in place to detect any form of money laundering relating to the proceeds of any crime and the financing of terrorism. All reference to anti-money laundering includes counter-terrorist funding.

The controls cover:

• Detailed AML procedures maintained in each Lilion Transfer company, affiliate or partner operating a Lilion Transfer service subject to AML legislation;
• Verifying the identity of customers, dealers and agents and obtaining additional know your customer (KYC) information as appropriate;
• Monitoring of customer transactions for activity that may be linked to money laundering or financing of terrorism;
• Procedures for the reporting of suspicious customer activity, both internally to the Money Laundering Reporting Officer (MLRO) and externally to relevant law enforcement bodies;
• Maintaining appropriate records of customer identification and transactions;
• Education and training of relevant employees.

It is the responsibility of each Local Company Chief Executive officer to set up appropriate processes and it is the obligation of all Lilion Transfer employees to familiarise with these controls.