KILC
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反恐怖融资政策

最后更新：05/11/2025

Counter-Terrorist Financing Policy

Effective Date: 05/11/2025 · Last Updated: 05/11/2025 · Version 1.1

1. Policy Statement

Keane International Legal Consultancy LLP (KILC) has zero tolerance for money laundering, terrorist financing, proliferation financing, sanctions evasion or any predicate offence. KILC will proactively prevent, detect and disrupt the use of its services for illicit purposes, exceeding minimum UK legal requirements where proportionate.

2. Scope & Application

This policy is mandatory for all directors, partners, officers, employees, contractors, agents, introducers, intermediaries and any entity acting on KILC's behalf, globally. It applies to all client relationships, transactions, referrals, advisory services, file openings, funds handling and data processing.

Non-compliance is gross misconduct and may lead to termination, regulatory referral and/or criminal prosecution.

3. Legal & Regulatory Framework

KILC complies with all applicable laws including but not limited to:

KILC will immediately adopt any stricter jurisdictional requirement (e.g. FATF standards, host-country law). Legal & Compliance team monitors legislative change in real time via automated regulatory feeds; policy auto-updates within 48 hours of material change.

4. Key Roles & Responsibilities

Senior Management (Partners): Ultimate accountability; approve policy; allocate unrestricted budget; receive monthly MLRO dashboards; conduct annual policy sign-off.

MLRO (Lisa Mao): Independent authority to block transactions, freeze funds, submit SARs without Partner approval, terminate clients. Reports directly to Partners; no business-line reporting.

Deputy MLRO: Fully trained alternate; assumes all MLRO powers in absence.

All Staff: Mandatory immediate reporting of suspicions; annual certification of compliance; personal liability for tipping-off.

5. Enterprise-Wide Risk Assessment (EWRA)

Annual mandatory EWRA + event-driven refresh (e.g. new service, jurisdiction). Quantitative scoring model (0-100) for:

Automated risk engine flags score ≥65 → EDD mandatory. All EWRA scoring decisions and overrides shall be documented and retained for 7 years for audit and regulatory inspection.

6. Customer Due Diligence (CDD)

All new clients: Electronic ID&V (e.g. GBG, LexisNexis) + biometric liveness check + proof of address ≤3 months.

Funds receipt: Source of Funds (SoF) documentary trail to original bank statement level.

Ongoing relationship: 12-month refresh for low-risk; 6-month for medium; real-time for high.

Prohibited: cash >£500, bearer instruments, third-party payments without pre-approval.

7. Enhanced Due Diligence (EDD) – Mandatory Triggers

EDD Actions (all cumulative): Senior Partner sign-off (cannot delegate); Independent SoF/SoW report by external forensic accountant; Transaction pre-approval workflow; Real-time transaction monitoring for 24 months.

8. PEPs, RCAs & State-Owned Entities

Lifetime PEP status (no de-classification). Mandatory EDD + annual SoF refresh. Prohibited: acceptance without unanimous Partner vote recorded in board minutes.

9. Sanctions, Proliferation & Watchlist Screening

Real-time screening (Dow Jones, Refinitiv World-Check) at onboarding, each payment instruction, and every 24 hrs for ongoing clients. Fuzzy logic + AI false-positive reduction; zero tolerance for matches → auto-freeze + MLRO review within 2 hrs. OFAC 50% rule applied to beneficial owners.

10. Ongoing Monitoring & Transaction Surveillance

AI rules engine flags: velocity, layering, smurfing, round-sum, rapid movement, geographic mismatch, U-turn transactions. Daily exception queue → MLRO review within 4 hrs. Client re-risking on every flag.

11. Suspicious Activity Reporting (SAR)

Internal reporting deadline: same day (secure channel only). MLRO 24-hr investigation window; SAR submission ≤2 hrs post-decision. Tipping-off = instant dismissal + NCA referral. Defensive SARs encouraged for borderline cases. Record-keeping: 7 years post-relationship end in WORM storage.

12. Training & Competence

Induction (Day 1) + annual 4-hr scenario-based training + quarterly phishing/AML tests. Pass mark 90%; failure → suspension until re-pass. MLRO delivers PEP/SoF masterclass bi-annually.

13. Independent Assurance

Annual external AML audit by Big-4 or equivalent. Penetration testing of CDD/monitoring systems. Partner-level remediation sign-off within 30 days.

14. Third Parties, Introducers & Outsourcing

Written due diligence file (including their EWRA, MLRO interview). Contractual clawback for AML breach. Right to audit their client files on demand. Zero reliance – KILC always performs full CDD. Third-party introducers must certify that they are not subject to sanctions or regulatory investigations.

15. Governance, Review & Breach Protocol

Quarterly AML Committee (minutes to Partners). Policy auto-review trigger: legislative change, material breach, new product.

Breach escalation matrix:

This policy shall be reviewed annually by external counsel to ensure continued compliance with UK law, FATF recommendations, and emerging international standards.

16. Prohibited Activities (Red Lines)

17. Practical Checklists (Mandatory Use)

A. New Client Onboarding:

B. Payment Receipt:

18. Appendix – Definitions

CDD/EDD/PEP/MLRO/SAR as per MLRs + KILC enhanced definitions above.

SoF: documentary evidence to original wealth creator.

SoW: corroborated explanation of economic activity.

19. Contact & Emergency Escalation

MLRO: Lisa Mao, +44 7412 121 232

24/7 Hotline: +44 800 123 4567 (recorded, MLRO voicemail)

NCA SAR: online portal (bookmark mandatory)