Introduction and Scope

Australian law and applicable local laws in the jurisdictions in which we operate, require us to put training, processes, and systems in place to identify, manage and mitigate the potential risk for used to launder money and finance terrorism. We do this to protect our reputation, comply with relevant laws and be good corporate citizens. Failure to do so may result in social harm, and significant penalties, including legal and regulatory action.

Stamsel (Uranus Pty Ltd) is committed to meeting its regulatory obligations in identifying,mitigating and managing money laundering and terriorist financing risk. It seeks to protect its customers, emplotees and the community from ML/TF activites and recognises that it can plays a critical role in this regard.

Our AML/CTF policy

•Sets out how Stamsel complies with its legislative obligations
•Applies to all business divisions, employees, and customers in Australia or overseas.

Definitions

Money laundering is the process of hiding or disguising the source of illegally obtained (“dirty”) funds to make them appear legitimate (“clean”), e.g., by filtering them through the financial system.
Money laundering reduces the risk of detection and confiscation by authorities. It is just as serious as the criminal activity behind it – and preventing it can help reduce crime.

Terrorism financing differs from money laundering in 3 main ways:
Its primary purpose is to disguise the ultimate use of the funds, as opposed to their origin
It can involve relatively small sums of money, which can have a huge impact in terms of death, destruction, and disruption
Although terrorists may finance their activities through crime, legitimate funds can also be misappropriated to finance terrorism.

Customer identification
The AML/CTF Act provides a list of ‘designated services’, such as signup an account or making a transaction. Before receiving any of these designated services, customers will be required to provide proof of identity or similar documentation.
Stamsel is required to collect and verify this information through Sumsub KYC / KYB, depending on the type of customer:
•Personal - an individual person of any nationality
•Sole trader - a person who trades in their own legal right without the use of a company structure, incorporation, or partners and who, alone, has full liability for the activities of the business
•Domestic company - incorporated in Australia, including proprietary, public, and listed public companies
•Foreign company incorporated outside Australia
•Partnership - a relationship between persons (the partners) carrying on business in common, under a partnership agreement, with a view to profit
•Trust - a relationship where the trustee holds property or assets for a beneficiary. The trustee can be an individual, a group of individuals or a company.
•Association - a group of persons who have agreed to join in pursuit of one or more common objectives. An association can be incorporated or unincorporated.
•Registered co-operative - a legal entity owned and controlled by the people for whom it was established and who benefit from using its services
•Government body - can be domestic (e.g. Commonwealth, State, Territory) or foreign government body.
Please note that Stamsel complies with the National Privacy Principles. For further details please refer to our Privacy Policy.

AUSTRAC
AUSTRAC is Australia’s AML/CTF regulator.

Suspicion
Money laundering and terrorism financing (ML/TF) are sometimes detected because a customer acts in a suspicious way or owns a high-risk identity.
For a ‘suspicion’ to be valid, we must have reasonable grounds to believe ML/TF activity may be occurring. To support this, compliance officers receive online training from the AUSTRAC website in identifying and reporting suspicious matters.

AML/CTF principles

• •Enrolment and Registration with AUSTRAC
• •Work in conjunction with the Australian Government and the governments of the countries we operate in, and support their objectives in relation to the prevention, detection, and control of ML/TF.
• •Maintain and comply with AUSTRAC AML/CTF program, as required by Australian AML/CTF legislation.
• •Comply with AML/CTF legislation in the countries we operate in.
• •Strive to fulfil international standards as detailed in the recommendations of the Financial Action Task Force (FATF).
• •Stamsel may decide not to provide products or services based upon decisions guided by ML/TF risk appetite and corporate social responsibility.

Policy roles and responsibilities

Stamsel Board of Directors (the Board) have ongoing oversight of our AML/CTF policy and procedures. All permanent and temporary employees must comply with these, attend training specific to their role, and report suspicious matters or behaviours.
We have a dedicated AML/CTF compliance officer responsible for monitoring the status and effectiveness of Stamsel’s AML/CTF risk management and compliance and reporting suspicious matters to AUSTRAC.
The AML/CTF compliance officer maintains Stamsel’s AML/CTF policy framework.

AML/CTF program

Stamsel maintains its AML/CTF policy program outlined by AUSTRAC and applies specific systems and controls, including:
•Schedule ML/TF risk assessment check by our independent reviewer (our accountant)
•Internal employee training organised by AML/CTF compliance officer,
•Employee and customer due diligence through Sumsub KYC/KYB services
•Transaction monitoring

Monitoring and reporting

As required by legislation, we report the following information to AUSTRAC:
•False identification information through our KYC/KYB
•Unusual rapid movement of funds in significant amounts
•Any transactions or other activities regarded as suspicious

* Updated 09/09/2022