Anti-money Laundering Policy (AML)
Set Jet Anti-money Laundering Policy Guidelines
The phrase “money laundering” covers all procedures to conceal the origins of criminal proceeds so that they appear to originate from a legitimate source. Set Jet, LLC (“Company”) aims to detect, manage and mitigate the risks associated with money laundering and the financing of terrorism. The Company has introduced strict policy aimed on the detection, risk prevention or mitigation in respect of any suspicious activities performed by Members.
The Company is required to constantly monitor its level of exposure to the risk of money laundering and the financing of terrorism. The Company believes that if it knows its client base (“Members”) well and understands its instructions thoroughly, it will be better placed to assess risks and spot suspicious activities.
Member Due Diligence
Effective Member Due Diligence (”MDD”) measures are essential to the management of money laundering and terrorist financing risk. MDD means identifying the Member and verifying their true identity on the basis of documents, data or information both at the moment of starting a business relationship with Member and on an ongoing basis. The Member identification and verification procedures require, first, the collection of data and, second, attempts to verify that data.
During the Set Jet Member registration process, individual members provide the following identification information to the Company:
- Member’s Full Name;
- Member’s Date of Birth;
- Member’s Full Address;
- Member’s Mobile Telephone Number and E-mail;
- Member’s Driver’s License or Passport Number;
- Member’s Social Security Number;
- Member’s Credit Card;
Once this information has been collected, Set Jet performs ID Verification, Criminal Background Check and Financial History Verification through our risk management solutions provider, LexisNexis.
If a member fails the electronic ID Verification, Criminal Background or Financial History check, the Company’s staff will manually verify this information requesting the appropriate ID verification documents. Appropriate documents for manually verifying the identity of Member include, but are not limited to, the following:
- A high resolution scanned copy or photo of pages of a passport or any other national ID, indicating family name and name(s), date and place of birth, passport number, issue and expiry dates, country of issue and Client’s signature.;
- A high-resolution copy of a utility bill (fixed-line phone, water, electricity) issued within the last 3 months;
- A copy of a bank statement (for a current account, deposit account or credit card account);
- A copy of a bank reference letter. When making a funds deposit or funds withdrawal via credit/debit card a Member is required to provide a scanned copy or photo of the credit/debit card (front and back side). The front side of credit/debit card should show the cardholder’s full name, the expiry date and the first six and the last four digits of the card number (the rest of the digits may be covered). The copy or scan of the reverse side of credit/debit card should show the cardholder’s signature, but the CVC2/CVV2 code must be masked. If an existing Member either refuses to provide the information described above or if a Member has intentionally provided misleading information, the Company, after considering the risks involved, will consider closing any of an existing Member’s account. The Regulations measures require further research and identification of Members who may pose a potentially high risk of money laundering/terrorism financing. If the Company has assessed that the business relationship with a Member pose a high risk it will apply the following additional measures:
- Obtaining the information relating to the source of the funds or the wealth of the Member will be required (this will be done via e-mail or phone);
- Seek further information from the Member or from Company’s own research and third party sources in order to clarify or update the Member’s information, obtain any further or additional information, clarify the nature and purpose of the Member’s transactions with Company.
When obtaining information to verify the Member’s statements about source of funds or wealth, the Company’s staff will most often ask for and scrutinise details of the person’s employment status or business/occupation.
The Company’s staff will ask for whatever additional data or proof of that employment/occupation that may be deemed necessary in the situation, particularly the appropriate confirming documents (employment agreements, bank statements, letter from employer or business etc.).
The Company will conduct ongoing Member due diligence and account monitoring for all business relationships with Members. It particularly involves regularly reviewing and refreshing Company’s view of what its Members are doing, the level of risk they pose, and whether anything is inconsistent with information or beliefs previously held about the Member. It can also include anything that appears to be a material change in the nature or purpose of the Member’s business relationship with Company.