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Anti-Money Laundering and Anti-Terrorist Financing Policy and Procedures

1. Introduction

The legislation on the prevention of the use of the financial system for money laundering and terrorist financing (hereinafter referred to as the AML/FT legislation or AML, for Anti Money Laundering ) imposes duties and obligations on financial institutions and their collaborators. Failure to comply with the legal requirements may result in a criminal penalty.

Each collborator should be aware that he or she may be held personally liable for failure to comply with the measures outlined in this policy.

AML policies are established in order to comply with the applicable Belgian and European legislation, but also with the recommendations issued by the Belgian, European and international supervisory authorities, as well as by the various working or action groups in the field of money laundering and terrorist financing. For example, the Financial Action Task Force (FATF) or the European Banking Authority.

This document describes the policies and procedures implemented by the company in the context of the fight against money laundering.

2. Policy

The company adopts the following principles as its AML policy:

  1. Definitions of "money laundering", "illicit origin" and "terrorist financing
    The company ensures that its collaborators understand what constitutes money laundering, illicit origin or terrorist financing.

  2. Appropriate AML governance and internal organization
    The company has a senior AML manager in the form of the Chairman of the Executive Committee who steers the company's AML policy. The company also appoints an AMLCO in the person of the Compliance Officer who monitors the company's compliance with AML regulations.

  3. AML risk management integrated into overall risk management
    AML risk is one of the many risks to which the company is exposed. For the sake of consistency, AML risk management is an integral part of, and complies with, the risk management framework and the company's overall risk management policy and procedures.

  4. An individual AML risk assessment for each client
    The company maintains a structured AML risk assessment form for each client in its computer system that includes client, geography, transaction, and channel risk, as well as a total client AML risk score of "low," "standard," or "high.

  5. Intolerance of suspicious and disproportionately risky AML situations
    The company shall not enter into business relationships with persons about which it has concerns (e.g., authenticity, legality, legitimacy of activities) or with a "high risk" of BC/FT, as defined in its AML risk assessment procedures.

  6. Identification of clients and their beneficial owners
    The company identifies its clients and, if applicable, their beneficial owners, verifies their identification data, as well as the presence of these persons on financial embargo lists.

  7. Retention of documents
    The company keeps a copy of all documents related to the identification and operations performed.

  8. Constant AML vigilance
    The company exercises constant vigilance with regard to business relationships and transactions between the company and its clients. For example, each time the company updates its embargo or financial sanctions lists, it assesses whether any of its clients appear on them.

  9. Staff training
    The company's collaborators are made aware of the AML subject through internal training provided by AMLCO or external training provided by recognized institutions (e.g. Febelfin).

  10. Internal and external cooperation on AML topics
    The company cooperates actively and usefully, both internally through the client service staff with the Compliance Officer, and externally, through the Compliance Officer with the Financial Information Processing Unit (CTIF), by communicating all atypical operations and responding to requests for information.

  11. Specific AML policies and procedures
    In order to control AML risks, the company has specific policies and procedures for client acceptance, identification of client characteristics and the nature of their business relationship, updating of client files, vigilance with regard to atypical transactions, reporting of atypical operations internally and externally to CTIF, and compliance with financial sanctions. All these policies and procedures are the subject of separate documents.

3. Procedures

The following procedures implement the principles of the company's AML policy.

3.1. Definitions

3.1.1 Money Laundering

Money laundering activities involve conduct of an intentional nature relating to :

3.1.2 Illicit origin

The origin of capital or property is illicit when it comes from the realization of a related crime:

3.1.3 Financing of terrorism

Terrorist financing is the raising or providing of funds or other material means, by any means, directly or indirectly, with the intent that they be used or knowing that they will be used, in whole or in part, by a terrorist organization or by a terrorist acting alone, even if not linked to a specific terrorist act.

3.2. Governance: AMLCO, Compliance Officer and internal organization

3.2.1 Senior AML = Chairman of the Executive Committee

In order to comply with AML legislation, the company has designated a senior person responsible for the prevention of money laundering and terrorist financing (i.e. the "senior officer responsible for AML") in its executive committee, in the person of its president.

Its role is to verify that operational measures are taken and to ensure that they are proportionate to the conclusions of the overall AML/CFT risk assessment.

3.2.2 Frontline MLA = Commercial Department

The sales department acts as the primary source of information and defense in terms of AML. In fact, it is the commercial collaborators who draw up an individual AML assessment sheet for each client and report the observed risks to the Compliance Officer.

3.2.3 AMLCO = Compliance Officer

In addition to the senior officer responsible for AML, the company appoints an AML committee (i.e. "AMLCO") is in charge of the application of the AML policy and procedures within the company as well as the awareness and training of collaborators.

In view of the company's size and risk profile, the company appoints the Compliance Officer as AMLCO. The Compliance Officer is therefore responsible for all regulated tasks usually assigned to the AMLCO.

The Compliance Officer regularly reports on AML matters to the senior officer responsible for AML, the Chairman of the executive committee.

3.2.4 Right of initiative and independence of the Compliance Officer

It is worth recalling here a basic principle, namely that the Compliance Officer has every right of initiative and independence in respect of checks, reviews and actions relating to AML matters.

Although in his investigative duties the Compliance Officer may call upon the various departments and management bodies of the company to clarify his understanding or refine his opinion, it is he in fine who decides on the controls and actions to be taken in terms of AML, in particular when he considers that an atypical transaction is suspicious and must be reported to CTIF.

3.2.5 Reactive and proactive

The Compliance Officer does not only play a reactive role when a transaction or an atypical fact is reported to him.

He also plays a proactive role in identifying atypical transactions. For example, he receives periodic and automatic reports from the company's IT system highlighting transactions that appear to be atypical, according to a list of criteria that the Compliance Officer defines in collaboration with the IT department.

Through these automated reports, the Compliance Officer is alerted to transactions that are "red flags" and should be subject to a thorough due diligence review by the Compliance Officer.

3.3. Overall assessment of the company's AML risks

In accordance with applicable legislation, the company adopts an AML Comprehensive Risk Assessment (CRA) approach that is integrated with the overall corporate risk assessment.

This global assessment of AML risks is carried out each year and is available in the company's risk management tool using the framework 1 next :
  1. Identification: description and classification of existing and emerging AML risks;

  2. Impact analysis:  quantitative and qualitative assessment of probability and severity;

  3. Appetence:  explicit choice of the board of directors on the tolerance of the impact ;

  4. Diffusion:  existing mitigation measures, including residual risk assessment;

  5. Monitoring:  evaluation of the sufficiency or inadequacy of the reduction measures;

  6. Reporting: communication and trace of the AML global risk analysis report;

  7. Answer: ambitious action plan when a dissemination measure is insufficient ;

  8. Recovery: reassessment of the overall AML risk assessment on an annual basis.

As part of this overall AML risk assessment, the company takes into account the characteristics of its clients, the products, services, transactions or operations it offers, the countries or geographical areas concerned, and the distribution channels it uses.

Each risk is evaluated according to an evaluation grid. The assessment focuses on the likelihood of the risk occurring and the severity that an occurrence of the risk would represent for the company.

This analysis leads to an overall exposure of the company to each individual risk. This global exposure to a risk can be "low", "standard" or "high".

The company then assesses its appetite for taking each risk. In particular, if the company wants to be tolerant of an overall risk that is assessed as high, the company will have to implement risk reduction measures that will have the effect of reducing the overall residual risk to standard or low.

If the residual risk remains high, the company's risk management policy is to manage this risk by refusing to accept this risk situation and therefore refuse to enter into a relationship with a client who would be in a high risk situation. This type of risk must be managed with heightened vigilance and these heightened vigilance measures are that the company would rather not take any risk and refuse the client.

If the risk is standard (also called "normal risk" or "ordinary risk"), the company may adopt ordinary vigilance measures. If the risk is low, the company may adopt simplified due diligence measures.

3.4. Individual assessment of each client's AML risk

For each client, the company's sales department fills out an AML information sheet in its computer system.

This fact sheet assesses the total AML risk of a particular client through approximately 20 questions. The questionnaire assesses the risk in terms of the nature of the client, the geography, the nature of the operations and the distribution channel:

*AML Client

Collaborator Knows Person?


Intermediary Relationship Context


Is ID verified?


All Data Obtained?


Incomplete Data Reason


Is Traded?


Relationship involves PEP?


Financial Sanctions List


Is On Financial Sanction List?


AML Client Risk


*AML Transaction

Funds Origin


Funds Origin Context


Is Transaction Amount > 250.000€?


Is Transaction Amount > 1.000.000€?


Is Proportionate Transaction?


Not Proportionate Transaction Reason


Is First Transaction Of Kind?


Same Transaction Of Kind Context


Payment Done From


Is Payer Currency Exchange?


Currency Exchange Name


Third Party Payer Relationship


Clients Acts In Own Name?


Clients Acts For Third Party


Accepts Proccessing Time?


Not Accepts Processing Time Reason


Is Transaction Normal?


Not Normal Transaction Reason


AML Transaction Risk


*AML Geography

Has Address?


No Address Reason


AML Geographic Region


AML Geographic Risk


*AML Channel

Is Physically Identified?


Is Authentified?


AML Channel Risk


*AML Summary

Is AML Accepted?


Additonnal AML Comments


Is Declared to CTIF?


AML Global Risk


Based on the answers provided, the system calculates a total client AML risk. This risk can be "low", "standard" or "high". The company refuses to do business with clients who have a "high" AML risk.

In particular, the reader will find in this document an in-depth explanation of the company's own AML risk assessment framework.

The AMLCO and the Senior AML Manager receive a weekly AML report from the company's computer system. This report will highlight the distribution of the company's clients into low, standard or high risk AML categories, as well as clients for whom the AML profile is non-existent or incomplete.

Total number of clients over the past period




Legal entities


Low risk clients


Standard risk clients


High risk clients


Clients domiciled in Belgium


Clients domiciled in the EU


Clients domiciled outside the EU


Clients domiciled in high risk countries AML


Clients identified in physical presence


Clients identified remotely


PPE clients


EPP clients Belgium and non high risk countries


EPP clients from high-risk countries


Production totale


New contracts in the past calendar year


Number of internal reports on atypical transactions


Number of declarations to CTIF


Number of cases subject to financial sanctions or emargos


In addition, each time a client becomes a "high" AML risk in the computer system, the AMLCO will be alerted by e-mail in order to take the necessary measures quickly. This alert can, for example, be triggered by an employee of the sales department who modifies the client's AML file, the program that checks the presence of the company's clients on the embargo list on a daily basis, or the program that checks the geographical origin of fund transfers to client portfolios (e.g. from Luxembourg).

3.5. Evaluation and update

The company shall ensure the effectiveness of the measures implemented to combat money laundering and terrorist financing in order to identify any shortcomings and remedy them.

This AML policy and procedures, and the detailed AML policies and procedures derived from it, are reviewed by the AMLCO annually or when there is a material change that affects the company's ability to apply the terms and conditions defined. They are validated by the Executive Committee and approved by the Board of Directors.

3.6. Monitoring compliance with policies and procedures

The Compliance Officer is responsible for enforcing this policy and implementing these procedures within the company.

Anti-Money Laundering and Anti-Terrorist Financing Client Acceptance Policy

1. Introduction

The company must determine the conditions under which it agrees to enter into a business relationship with its clients or to intervene in the execution of occasional operations for its clients. It must therefore provide a framework for the decision-making process regarding the entry into a business relationship or the execution of the occasional operation, and regarding the nature and intensity of the vigilance measures to be implemented. This document describes the policy and procedures for accepting clients under the lens of the anti-money laundering and terrorist financing (i.e. AML) regulations.

2. Policy

The company adopts the following principles as its client acceptance policy from an AML perspective:


Policy and procedures for identifying client characteristics and business relationships

1. Introduction

The company must identify each client, its characteristics, the purpose and nature of the relationship. The company shall develop principles and procedures for identification and verification, based on the risks of each individual situation.

2. Policy

The company adopts the following principles as its policy regarding the identification of client characteristics, purpose and nature of the business relationship:

  1. Identification of client characteristics
    In addition to formal client identification data, the company also collects and processes data that relate to other client characteristics, such as socio-demographic data, behavioral data, and AML interest data (e.g. PEP, UBO).

  2. Special measures for PEP
    Specific measures are taken with regard to Politically Exposed Persons (PEP), notwithstanding their country of residence.

  3. Special measures for UBOs of legal persons
    For legal entity clients, the company identifies all of its beneficial owners (UBOs), whose suitability in terms of AML is also assessed (e.g. Are they PEP? Are they subject to financial sanctions?).

  4. Identification of the nature of the business relationship
    The firm determines why the client is a client. In particular, does the client use portfolio management and/or life insurance intermediation? Does the client want to grow his capital over the long term or generate a short-term annuity from his capital invested with the firm?

Policy for periodic review of clients and updating of their data

1. Introduction

The company must ensure that information regarding the identity of its clients, documents to verify that identity, and any data of interest to AML is current. The following document describes the policy and procedures for updating client data.

2. Policy

The company adopts the following principles as its policy for updating and periodically reviewing client data:

  1. Importance of having up-to-date data
    In order to participate effectively in the fight against money laundering and terrorist financing, it is important that the company be able to detect atypical transactions based on current information. More generally, the company must maintain up-to-date data in its IT system in order to offer relevant services to its clients.

  2. Items to be updated
    The firm maintains the information collected in connection with the identification and verification of the identity of clients, their characteristics, and the purpose and nature of the business relationship or proposed transactions. The firm considers that MiFID information is an integral part of the business relationship and must also be kept up to date.

  3. Frequency and modalities of the update
    Client data is updated at different frequencies depending on the type and importance of each data. Some data is updated over the course of the client relationship by an advisor (e.g. change of address), others are updated at least once every 5 years (e.g. MiFID profile), others are updated daily in an automated way on critical AML elements (e.g. financial sanctions verification).

  4. Governance and rigor in updating
    The company's sales department, through its client service function, is responsible for updating all client data. For certain data of interest to AML, the Compliance Officer is responsible for ensuring that the data is properly updated, if necessary through an automated computer program. When updating this information, the company applies the same degree of rigor and seriousness as for the initial collection of information before the start of the business relationship.

  5. Power to terminate the relationship
    If the client does not comply with the request to update the data, the company reserves the right to terminate the business relationship.

  6. Update, then review, then action
    Updating is not an end in itself. Each update must be reviewed, even if only briefly, of the general impact and, more specifically, of the risks (AML or other) incurred by the company as a result of the change. This review may lead to specific actions to be taken (e.g., signing an updated portfolio management agreement or reporting an atypical transaction to AMLCO).

Client Transaction Due Diligence Policy

1. Introduction

The company must carefully examine the financial operations and transactions carried out by its clients during the business relationship. This obligation aims to monitor occasional operations of clients and to pay attention to intriguing facts and atypical transactions which, if they are suspicious, must be reported to CTIF.

2. Policy

The company adopts the following principles as its client transaction due diligence policy:

AMLCO Internal Atypical Transaction Reporting Policy

1. Introduction

When atypical facts or transactions are detected, the collaborator must report them to the AMLCO (i.e. the Compliance Officer), so that the latter can carry out an analysis and, if necessary, ensure that the company complies with its obligation to report suspicious transactions to CTIF.

2. Policy

The company adopts the following principles as its internal policy for reporting atypical transactions to AMLCO:

  1. AMLCO = Compliance Officer
    The company's AMLCO is its Compliance Officer.

  2. Systematic reporting
    Whenever an atypical transaction is detected - and without exception - the collaborator reports it to the Compliance Officer.

  3. Timeliness of reporting
    When an atypical transaction is detected, the collaborator informs the Compliance Officer as soon as possible.

  4. Complete and structured reporting
    The collaborator will provide the Compliance Officer with complete and structured information concerning the transaction, its context and the client's context.

Financial Sanctions Compliance Policy

1. Introduction

The company must frequently verify whether or not its clients are on national and international financial sanctions lists.

2. Policy

The company adopts the following principles as its policy in terms of financial penalties:

  1. List of verified databases
    The company verifies the presence of its clients in the official freeze list of the Belgian Government, the European Union or the UN.

  2. Automation and criteria for matching
    The company implements an automated checking algorithm within its IT infrastructure to compare the names of its clients with those in the above-mentioned databases.

  3. Periodicity of the checks
    The verification algorithm runs once a day. The result of the algorithm is systematically sent as a report by e-mail to the AMLCO (i.e. the Compliance Officer), the senior office responsible for AML (i.e. chairman of the board), and the head of the commercial department.

  4. Action plan in case of a match
    The AMLCO (i.e. the Compliance Officer) has a clear plan of action in case of suspicion of a client in one of the monitored databases, including a possible report to CTIF.

  5. Collaboration with the custodian
    The company collaborates with its custodian in the identification of the presence of its clients on sanction lists. In fact, the custodian has the same obligations but perhaps different procedures that are complementary to those of the company and reinforce the respect of these obligations.

1 The RME framework presented by the National Bank of Belgium (NBB) foresees 3 steps: (1) Identify the risks, (2) Analyze the risks, and (3) Frame / reduce the risks.

In order to maintain a single risk management framework within the company, the company has chosen not to use exactly the same framework with the same names as that of BNB, but to maintain the risk management approach structure that it uses for the assessment of all its risks.

Of course, the company's approach covers all the points recommended and required by the NBB. Only the denominations are different. The spirit recommended by the NBB behind the overall AML risk assessment is also strictly observed.

Easyvest is a brand of EASYVEST NV/SA, with company number 0631.809.696, authorized and regulated by the Belgian Authority for Financial Services and Markets (FSMA) as a portfolio management company and as a broker in insurances, with registered office at Rue de Praetere 2/4, 1000 Brussels, Belgium. Copyright 2024 EASYVEST NV/SA. Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections may not reflect actual future performance. All securities involve risk and may result in loss.