AML / CFT Policy

Portman International adheres to a high standard of Anti-Money Laundering and Counter Financing of Terrorism compliance in order to safely meet the regulatory obligations at both national and international level. We adopt robust client acceptance and customer due diligence procedures, implementing regulatory measures at on-boarding stage as well as throughout the business relationship. We endeavour to assist clients with their compliance requirements in different countries. We share our opinion with clients on the regulatory risk profile of the proposed structure and activity as this may be an area they may have overlooked.

Client Acceptance and Customer Due Diligence

Understanding the applicant for business and the business relationship are of utmost importance. At Portman International we have converted the statutory rules and regulations into our Compliance Handbook in order to aid clients with our requirements in an understandable and straight forward way. The main areas of focus being the following:

  • Identification and verification of the applicant for business;
  • Identification and verification of the beneficial owner or any other person whom has significant control;
  • Assessing and validating the purpose and intention of the business relationship;
  • Conducting on-going monitoring of the business relationship to ensure that all data is kept relevant and updated;

All documents, data and other forms of information are obtained from reliable, independent and credible sources in order to ensure authenticity. It is this data that then comes together to form the risk profile of the proposed activity and stake holders. In doing so Portman International adopts an evidence-based decision making methodology which runs through all the internal compliance policies that we have in place.

Risk-based approach

Risk itself is variable in nature, and different permutations of variables may increase of decrease the potential risk posed. We therefore take into account several factors such as the purpose of the relationship, the level of assets introduced by the client as well as the regularity or duration of the business relationship. These factors are by no means exhaustive; other risk factors are taken into consideration which may have the effect of either mitigating or increasing the risk level in relation to the client.

Training and internal reporting

In order to properly meet the objectives set out in national and international law we have yearly AML / CFT training sessions for our staff members. This ensures that all Portman International staff are kept up-to-date with current procedures and requirements. This policy is supported by an effective internal reporting system that flags risk events to the compliance department and, most importantly, the flags any suspicious transactions to the Money Laundering Reporting Officer.

Sound compliance awareness within the company is of primary importance at Portman International. Our staff are well equipped to provide a service that not only satisfies the client but meets the requirements under AML / CFT law, thereby providing both a safe and secure business.