Anti-Money Laundering (AML) Policy
Global Unlimited Intertrade LTD
Effective Date: May 13, 2025
1. Introduction
Global Unlimited Intertrade LTD (“the Company”, “we”, “our”, “us”) is committed to preventing and detecting money laundering and terrorist financing through the implementation of effective policies and procedures in accordance with:
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The Prevention of Money Laundering Act (PMLA), 2018, and associated regulations in Malta;
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European Union (EU) Anti-Money Laundering Directives;
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Financial Action Task Force (FATF) Recommendations;
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Other applicable international laws and regulations.
This policy outlines the procedures that Global Unlimited Intertrade LTD follows to ensure compliance with Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) laws.
2. Objectives
The main objectives of this AML Policy are to:
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Prevent the use of Global Unlimited Intertrade LTDβs services for money laundering or terrorist financing;
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Ensure compliance with applicable national and international AML and CTF regulations;
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Detect and report suspicious transactions or activities;
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Establish a framework for due diligence, training, and monitoring to identify potential money laundering risks.
3. Definitions
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Money Laundering: The act of concealing the origin of illegally obtained money, typically by means of complex transactions or integration into the economy.
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Terrorist Financing: The provision of financial resources to support or carry out terrorist activities.
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Customer Due Diligence (CDD): The process of identifying and verifying customers and understanding the nature of their business and financial activities.
4. Risk-Based Approach (RBA)
Global Unlimited Intertrade LTD adopts a risk-based approach (RBA) in its AML procedures. This ensures that resources are applied proportionately to manage the risks identified, and that controls are adjusted based on the risk profile of customers, transactions, and regions. Risk factors considered include:
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Geographic location;
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Client type (individuals, corporates, PEPs);
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Industry sector;
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Complexity of financial transactions.
Customers identified as high-risk are subject to Enhanced Due Diligence (EDD).
5. Know Your Customer (KYC) Requirements
Global Unlimited Intertrade LTD ensures that all customers undergo Know Your Customer (KYC) checks, which involve:
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Verifying the identity of customers (via government-issued ID, passport, or company registration documents);
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Identifying and verifying the beneficial ownership for corporate entities;
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Understanding the source of funds for transactions;
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Screening customers against sanctions lists (e.g., UN, EU, OFAC).
6. Customer Due Diligence (CDD)
We carry out Customer Due Diligence (CDD) for all new customers and clients. This includes:
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Collecting and verifying the customer’s identification data;
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Establishing the purpose of the business relationship;
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Assessing the legitimacy of the client’s source of funds and wealth;
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Retaining customer records for at least five (5) years following the last transaction or closure of the relationship.
CDD will be conducted if:
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A new business relationship is being established;
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Transactions exceed established thresholds;
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There is suspicion of money laundering or terrorist financing;
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Information on the client appears inconsistent or outdated.
7. Enhanced Due Diligence (EDD)
In the following high-risk scenarios, Enhanced Due Diligence (EDD) is applied:
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For Politically Exposed Persons (PEPs) or their family members;
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In relation to clients or transactions involving high-risk jurisdictions (countries with poor AML/CTF controls);
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Where complex corporate structures or opaque ownership exists.
EDD may include the collection of additional data, approval from senior management, and increased scrutiny of transactions.
8. Monitoring and Reporting
Global Unlimited Intertrade LTD continuously monitors all transactions for signs of suspicious activity. Red flags include:
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Large or rapid movement of funds without clear business purpose;
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Unusual transactions involving high-risk countries or offshore accounts;
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Unexplained changes in customer behavior or financial patterns.
Any suspicious transactions are reported to the Compliance Officer and may be filed with relevant authorities, including the Financial Intelligence Analysis Unit (FIAU) in Malta.
9. Recordkeeping
Global Unlimited Intertrade LTD maintains comprehensive records related to AML activities, including:
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Identification and verification data for customers;
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Transaction records and supporting documentation;
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Suspicious activity reports (SARs);
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Internal and external audit reports.
Records are maintained for a minimum of five (5) years from the date of the last transaction or business relationship termination.
10. Training and Awareness
All employees of Global Unlimited Intertrade LTD undergo mandatory AML training upon hiring and at regular intervals thereafter. The training includes:
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Laws and regulations concerning money laundering and terrorist financing;
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Procedures for identifying suspicious activities;
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Reporting and record-keeping requirements;
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The internal escalation process for compliance issues.
Training effectiveness is periodically reviewed and updated.
11. Compliance Officer
The AML Compliance Officer is responsible for ensuring the implementation of this policy. Their duties include:
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Conducting regular risk assessments of the companyβs operations;
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Monitoring ongoing transactions for potential AML risks;
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Reporting suspicious activity to the relevant authorities;
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Ensuring AML training is provided to all relevant staff;
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Acting as the main point of contact for regulatory authorities.
12. Sanctions Compliance
Global Unlimited Intertrade LTD ensures that no business is conducted with individuals or entities on international sanctions lists (e.g., OFAC, UN Sanctions, EU Sanctions). We screen customers and transactions to ensure compliance with these sanctions.
13. Breach and Non-Compliance
Any employee or third party found to be involved in money laundering, terrorist financing, or non-compliance with this policy will face:
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Disciplinary actions;
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Immediate termination of their relationship with the Company;
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Potential reporting to law enforcement or regulatory bodies.
14. Review and Updates
This AML policy is subject to review and update on an annual basis, or whenever there are significant changes to the regulatory environment. All changes are approved by the Board of Directors.
15. Contact Information
For any questions or concerns about this AML Policy, please contact:
Compliance Department
Global Unlimited Intertrade LTD
π Mosta Road, Central Office Building, Block A, Level 0, Halmann Vella, LJA 9016 Lija, Malta
π +44 7514 013350
π§ office@globalunlimitedintertrade.com
