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| 6.1. | Statutory requirements | ||
HD Faculty™ requires
all subsidiaries and their respective nominee financial institutions carrying
on financial business to take appropriate measures to make employees whose
duties include the handling of financial business aware of: |
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(a) |
Policies and procedures maintained to
prevent money laundering including those of identification, record keeping
and internal reporting; |
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(b) |
The requirements imposed by
the law, and, also and to provide such employees with training in the recognition
and handing of suspicious transactions. |
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| 6.2. | The need for Client Care Personnel awareness | ||
The effectiveness of the procedures
and recommendations contained in the various Rules, Regulations, and other
relevant instructions issued by the Regulatory Authorities of the host
country on the subject of money laundering depends on the extent to which
Client Care Personnel of subsidiaries and their authorised agents, and/or
portfolio managers as appropriate appreciate the serious nature of the
background against which the law has been enacted and are fully aware of
their responsibilities. Client Care Personnel must also be aware of their
own personal statutory obligations. They can be personally liable for failure
to report information in accordance with internal procedures. All Client
Care Personnel must, therefore, be encouraged to co-operate and to provide
a prompt report of any knowledge or suspicion of transactions involving
money laundering. It is, therefore, important that subsidiaries and their
authorised agents, and/or portfolio managers as appropriate introduce comprehensive
measures to ensure that Client Care Personnel is fully aware of their responsibilities. |
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All relevant Client Care Personnel should be educated in the importance of “know your client” requirements for money laundering prevention purposes. The training in this respect should cover not only the need to know the true identity of the Client but also, where a business relationship is being established, the need to know enough about the type of business activities expected in relation to that client at the outset to know what might constitute suspicious activity at a future date. Relevant Client Care Personnel should be alert to any change in the pattern of a client’s transactions or circumstances that might constitute criminal activity. |
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| 6.3. | Employees to be trained, content, timing and methods of training | ||
As a means of assistance in
the discharge of their legal obligations, subsidiaries and their authorised
agents, and/or portfolio managers as appropriate should refer to these
Rules, Regulations, and Instructions, which deal with the recognition,
and reporting of suspicious transactions. |
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In addition to the above, subsidiaries and their authorised agents, and/or portfolio managers as appropriate are expected to establish a programme of continuous training for all levels of their Client Care Personnel. |
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The timing, content and methods
of training for the various levels or types of Client Care Personnel should
be tailored to meet the needs of the particular subsidiary and its portfolio
manager or custodian, depending on the size and nature of the respective host country’s HD Faculty™ and the available time and resources. |
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It will also be necessary
to make arrangements for refresher training at regular intervals to ensure
that Client Care Personnel do not forget their responsibilities. |
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