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Table of contents
Executive Summary
- Introduction
- Key Definitions
- Principles
- Purpose
- Role of Oica
- General Application of this policy
- Scope of Application - Activities
- Scope of Application - Persons
- Risk-Based Approach
- Risk-Based know your customer/counterparty (KYC) and due diligence
- Knowing the Customer/Counterparty
- Customer/Counterparty due diligence
- Beneficial Ownership
- Persons Convicted or Subject to Criminal Investigation
- Sanctioned and Debarred Persons
- Persons Linked to Organised Crime
- Persons convicted of illegal tax practices
- Politically Exposed Persons
- Reputationally Exposed Persons
- High Risk Persons
- Monitoring Projects where persons are subjected to enhanced due diligence (EDD)
- Use of fictitious names
- Suspicious Transactions
- Shell Banks
- Correspondent Banks
- Counterparty Compliance
- Notification of Compliance
- Financial Sanctions
- Retention of Records
- Training
- Review
- Oversight and Implementation