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Financial crime controls

AML and Fraud Procedure

Summary of Global RE Overseas Ltd procedures for anti-bribery and corruption, anti-money laundering, sanctions controls, and fraud prevention.

Compliance commitment

Global RE states that employees are expected to follow its code of conduct, internal compliance policies, and applicable laws. Management and compliance functions are responsible for embedding these requirements into business processes.

Financial crime risk areas

The procedure identifies four key compliance risk areas connected to financial crime and sanctions violations.

  • Anti-bribery and corruption
  • Anti-money laundering
  • International trade controls and sanctions violations
  • Fraud prevention, detection, and response

Control framework

The stated framework is built around policies, standards, processes, training, awareness, tools, monitoring, investigation, and reporting. Gifts, hospitality, due diligence, suspicious activity escalation, and sanctions controls are treated as controlled compliance processes.

Customer due diligence and monitoring

The procedure describes Know Your Client checks, beneficial ownership review, documentation requirements, risk-based monitoring, suspicious activity reporting, and record keeping. Business relationships are reviewed for unusual activity, source-of-funds concerns, complex ownership, and sanctions exposure.

Fraud and sanctions

Global RE states that it maintains policies and procedures to prevent, detect, and respond to fraud, and to comply with applicable sanctions and international trade control requirements.