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Internal Anti-Money Laundering Policy

INTERNAL ANTI-MONEY LAUNDERING POLICY

At VMS Energy de México we are committed to preventing and combating money laundering and terrorist financing by implementing effective measures that ensure compliance with relevant laws and regulations.

Know Your Customer (KYC)

  • Customer Identification: All customers must provide valid and verifiable identification documents prior to opening an account or conducting any significant transaction. Acceptable documents include passports, national IDs, and driver's licenses.

  • Identity Verification: The institution will carry out verification procedures to confirm the authenticity of identification documents. Verification technologies will be used, such as document validation through government databases.

  • Client Risk Assessment: Customers will be classified into risk categories (low, medium, high) based on factors such as occupation, source of funds, and geographic location. High-risk customers will be subject to closer monitoring

Transaction Monitoring

  • Monitoring System: A transaction monitoring system will be implemented that will detect unusual or suspicious activities based on predefined transaction patterns.

  • Activities Review: Transactions that exceed certain pre-established thresholds or show unusual patterns will be reviewed by compliance staff.

Suspicious Activity Reports

  • Reporting Procedure: Employees must immediately report any suspicious activity to the institution's Compliance Officer. A Suspicious Activity Report (SAR) must be filed if it is determined that the activity could be related to money laundering or terrorist financing.

  • Confidentiality: Reports and details related to suspicious activities must be treated with the utmost confidentiality.

Training

  • Initial Training: All employees will receive training on anti-money laundering policies and procedures upon onboarding.

  • Continuous Training: Ongoing training will be offered to keep staff up to date on the latest regulations and prevention techniques.

Internal Policies and Procedures

  • Documentation: All internal procedures related to the prevention of money laundering will be documented and updated regularly.

  • Policy Review: The policy will be reviewed and updated at least annually to reflect changes in legislation and best practice.

Audit and Review

  • Internal Audits: Periodic internal audits will be carried out to evaluate the effectiveness of anti-money laundering policies and procedures.

  • Corrective Actions: Areas of improvement identified during audits will be addressed through corrective actions.

Compliance and Sanctions

  • Responsibility: All employees have the responsibility to comply with this policy and applicable anti-money laundering laws.

  • Sanctions: Violations of this policy may result in disciplinary action, including termination of employment and legal action.

At VMS ENERGY, we affirm that we do not use resources of unlawful origin or finance terrorism.