Anti-Money Laundering (AML) Policy

1. Purpose
This Anti-Money Laundering (AML) Policy outlines the commitment of PMCT Accountants & Consultants to prevent and detect any money laundering activities in compliance with applicable laws and international standards. Our goal is to protect our business and clients from criminal exploitation and to maintain our integrity and reputation.

2. Scope
This policy applies to all directors, employees, agents, consultants, and contractors of PMCT Accountants & Consultants. It encompasses all services offered by the firm, including, but not limited to, accounting, taxation, consulting, training, and outsourcing services.

3. Definition of Money Laundering
Money laundering is the process of disguising the origin of illegally obtained money to make it appear legitimate. It typically involves three stages:

• Placement: Introducing illegal funds into the financial system.

• Layering: Concealing the source through complex transactions.

• Integration: Reintroducing laundered money into the economy as legitimate funds.

4. Legal and Regulatory Framework
PMCT Accountants & Consultants operates under the relevant anti-money laundering laws of Ghana, including the Anti-Money Laundering Act, 2020 (Act 1044), and complies with applicable international AML obligations, including FATF Recommendations.

5. Roles and Responsibilities

• Board of Directors: Responsible for ensuring a robust AML framework is in place.

• Compliance Officer (MLRO): Oversees AML implementation, monitoring, and reporting of suspicious activities.

• All Staff: Must be aware of AML responsibilities and report any suspicious transactions or behaviour to the Compliance Officer.

6. Know Your Customer (KYC)
We implement a risk-based KYC procedure requiring:

• Verification of client identity using official documents.

• Understanding the nature of the client’s business.

• Ongoing monitoring of client transactions and activities.

• Identification of beneficial owners for corporate clients.

7. Customer Due Diligence (CDD)
PMCT carries out three levels of CDD:

• Standard CDD: For low-risk clients.

• Enhanced Due Diligence (EDD): For high-risk clients or transactions.

• Simplified Due Diligence: In cases where risk is minimal (e.g., low-value services).

8. Record-Keeping
All customer identification documents, due diligence records, and transaction records will be maintained for a minimum of six (6) years by applicable legal requirements.

9. Suspicious Activity Reporting
All employees must report any suspicious transactions or behaviour to the MLRO immediately. The MLRO will assess the report and, if appropriate, file a Suspicious Transaction Report (STR) with the Financial Intelligence Centre (FIC) of Ghana.

10. Training and Awareness
All staff receive AML training upon joining and annually thereafter. Training covers AML obligations, identifying suspicious behaviour, KYC procedures, and internal reporting obligations.

11. Internal Controls and Audit
PMCT implements regular internal audits to assess the effectiveness of its AML controls. Findings are reported to the board and used to improve processes.

12. Breach of Policy
Failure to comply with this policy may result in disciplinary action, including termination of employment or contract, and could lead to legal action.

Contact Information
PMCT Accountants & Consultants
26 Flower Street, Tabora Number 2, Accra, Ghana
Tel: +233 200 843282
Email: info@pmctaccountants.com

Approved and signed by: Vincent Santeng
For PMCT ACCOUNTANTS & CONSULTANTS