The HIGIFT Anti-Money Laundering and Anti-Terrorist Financing (AML/ATF) and Sanctions Policy (the "Policy") establishes the AML/ATF and Sanctions Program that defines how HIGIFT and its affiliates comply with applicable laws and regulations, including the provisions of the USA PATRIOT Act as implemented in the Code of Federal Regulations Title 31: Money and Finance: Treasury Part 1028 Rules for Operators of Credit Card Systems, sanctions designated by the U.S. Office of Foreign Assets and Controls (OFAC), and export controls administered by the Commerce Department’s Bureau of Industry and Security (BIS). The Policy also takes into consideration recommendations from supranational bodies that promote international AML/ATF standards such as the Financial Action Task Force (FATF).
The Policy applies to HIGIFT (“Company”) and shall apply to all directors, officers, employees, and contingent workers of HIGIFT (“HIGIFT staff”).
HIGIFT shall maintain a global AML/ATF and sanctions policy and implementing procedures (also known collectively as the “Program”) reasonably designed, within the context of applicable laws and regulations, to prevent its network, initiatives, businesses, products and services from being used to facilitate money laundering or the financing of terrorist activities and to ensure compliance with applicable sanctions and export controls.
HIGIFT shall conduct its business in compliance with the economic sanctions and export control laws of the United States and other applicable sanctions laws worldwide.
The HIGIFT AML/ATF and Sanctions Officer, as the Policy Owner, administers the Policy and develops a policy framework that includes procedures, tools, training and communication to implement this Policy and achieve its objectives.
The Audit and Risk Committee of the HIGIFT’s Board of Directors ("ARC") is responsible for overseeing the Program and shall be notified of any material Policy exceptions. As such, HIGIFT 's AML/ATF and Sanctions Officer shall provide periodic reports to the ARC on the implementation of the Program. The Corporate Risk Committee (CRC) provides governance oversight for this Policy. The CRC is responsible for overseeing implementation of the Program, and its responsibilities include, but are not limited to:
The HIGIFT AML/ATF and Sanctions Officer has overall responsibility for the design and implementation of the Program. Specifically, he/she is responsible for:
HIGIFT’s Legal Team (“Legal”) is responsible for advising the HIGIFT AML/ATF and Sanctions Officer of legal and regulatory developments. Additionally, Legal is responsible for reviewing and approving all changes to the Policy and Procedures to ensure compliance with applicable regulatory requirements.
The Program is comprised of the following standards:
An HIGIFT AML/ATF and Sanctions Officer shall be designated by the CRC and is responsible for developing, implementing, and monitoring adherence to the Program, and updating it as necessary in response to changes in regulatory requirements or risk conditions.
Internal procedures and controls must be documented to:
Training and education of appropriate HIGIFT staff shall be provided periodically to help ensure staff’s awareness of their responsibilities under HIGIFT's AML/ATF and Sanctions Program.
Review The AML/ATF and Sanctions Program and the execution of its various components throughout HIGIFT shall be subject to periodic independent reviews conducted by Internal Audit and/or a qualified third party. The Program also shall be subject to periodic independent compliance testing.
The Policy Owner is responsible for reviewing the Policy at least annually to confirm that it remains relevant and is effective in meeting the stated business objectives, and recommending updates as needed to the CRC.