Anti-money laundering (aml)/ counter terrorist financing (ctf) policy

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1. Introduction

Vista has a zero-tolerance approach to Money Laundering, funding of terrorism, financing proliferation and is committed to the highest level of openness, integrity, and accountability. It will continue to improve and update its framework, systems, controls and procedures to prevent being used as a cog for the purposes of money laundering.

Vista will conduct business only with reputable Customers and Associated Persons, with funds derived from legitimate sources. Vista approach to laundering, counter terrorist financing and counter proliferation financing will be based on the below:

  • Customer Due Diligence (“CDD”)
  • Processes, Procedures and Controls
  • Designation of a compliance Officer
  • Training

Vista has established a comprehensive global AML programme and this policy is the foundation of such programme, setting minimum control standards to be implemented across all jurisdictions in which we operate.

In this Laundering Policy (“Policy”), “Vista” refers to Vista Group Holding Limited (a company incorporated in the United Arab Emirates, having its registered address at Unit GV11, L1, Unit 106, Level 1, Gate Village Building 11, Dubai International Financial Centre, Dubai, 507213, United Arab Emirates and with registration number 2953 and to all its affiliates companies and subsidiaries.

As per local requirements, this Group AML/CTF policy is complemented by local policies in all relevant jurisdictions, which will be informed by applicable laws, regulations, regulatory guidance, and best practice from the relevant country. In case of material discrepancy between the standards articulated in this Policy and local laws and regulations, Vista acknowledges the primacy law.

2. Purpose

The purpose of this AML/CTF Policy is to set Group standard for the identification, mitigation and management of the risks associated with money laundering and terrorist financing and the implementation of appropriate processes, systems, and controls.

  • Conduct due diligence on prospective customers and existing customers, taking a risk-based approach in terms of (i) onboarding documentation, and (ii) frequency of review;
  • Create a framework of transaction and activity monitoring;
  • Create awareness for effective laundering, based on training, competence and (adequate) information sharing;
  • Adequate and lawful record keeping, in compliance with applicable privacy legislation.

The identification of a customer and knowledge of the customer’s activities is not in itself, sufficient to protect an individual and Vista from breaching money laundering and the terrorist financing laws. There is an ongoing duty to be always vigilant with regards to money laundering and terrorist financing and to report any suspicious transactions or circumstances.

3. Scope

This Policy applies to:

  1. all employees, officers, directors and contracted personnel of Vista, and to such other persons as designated by Vista from time to time (each an “Employee”, collectively “Employees”); and,
  2. all natural and legal persons (and their respective employees, officers and directors) that perform services for or on behalf of Vista, including without limitation, supply chain business partners, suppliers, consultants, contractors, distributors and agents (including without limitation, sales agents/representatives), (each an “Associated Person”, collectively “Associated Persons”).

This document sets out responsibilities and governance standards in relation to legislation, regulatory obligations and risk management while providing information and best practice guidance to those working to protect Vista, its customers, shareholders and society.

This Policy is intended to supplement and not replace other Vista codes of conduct, policies, rules and procedures that are applicable to Employees and Associated Persons from time and time. If any Employee or Associated Person has any doubt as to the Vista codes, policies, rules and procedures applicable in a given situation, or if any Employee or Associated Person perceives any conflict or inconsistency between this Policy and any other Vista code, policies, rules or procedures, then he/she should raise the issue with, and seek direction from the Compliance and Ethics Department at This Policy is a statement of principles and expectations for individual and business conduct. It is not intended to and does not in any way constitute a contract, an employment contract, or assurance of continued employment, and does not create any right in any Employee or Associated Person. The enforcement and interpretation of this Policy rests solely with Vista. This Policy only creates rights in favour of Vista. The headings contained in this Policy are for convenience only and shall not be interpreted to limit or otherwise affect the provisions of this Policy.

Contracts and agreements executed between Vista and Associated Persons may contain more specific provisions addressing some of the issues set out in this Policy. Nothing in this Policy is meant to supersede any more specific provision in a particular contract or agreement executed between Vista and an Associated Person, and to the extent there is any inconsistency between this Policy and any other provision of a particular contract or agreement, the provision in the contract or agreement will prevail.

The examples, red flags, and case scenarios referred to in this Policy are not exhaustive or exclusive and are included solely as guidance. Employees and Associated Persons must be aware that there are other potential situations which may lead to money laundering or terrorist financing concerns.

In this Policy the term “Client” refers to a purchaser or prospective purchaser of Vista’s good and/or services.

4. Policy
4.1. Key Definitions
4.1.1 Money Laundering

Regulators in each jurisdiction that Vista operates will provide the local definition as per their regulation. For the purpose of this group Policy, money laundering is defined as the process by which criminally obtained money or other assets (‘criminal property’) are exchanged for ‘clean/legitimate money or other assets with no obvious link to their criminal origins. Money laundering can be used by terrorist organisations, drug dealers, those engaged in bribery, and by anyone who receives money through illegal activities.

Money Laundering activities includes but are not limited to the below and may differ according to domestic legislation:

  • Concealing: knowing or suspecting a case of money laundering but concealing or disguising its existence
  • Arranging: becoming involved in an arrangement to launder money or assisting in money laundering.
  • Acquisition, use or possession: benefiting from money laundering by acquiring, using or possessing the criminal property concerned.
  • Failure to disclose one of the aforementioned offences.
  • Making a disclosure to a person which is likely to prejudice a money laundering investigation (“tipping-off”).
  • Criminals involved in handling criminal property look for ways to secure and safeguard the proceeds of their criminal activities. Although, other ways exist, cash is the mainstay of criminal transactions, being the most reliable and flexible, and having little or no audit trail.

    In simplistic terms, money laundering normally consists of 3 stages:

    Placement Stage: the money derived from illegal activities is often initially introduced into the financial system by breaking up large amounts of cash into less conspicuous smaller sums that are then deposited directly into bank transfer, or purchasing a series of monetary instruments that are then collected and deposited into accounts at another location. This is the point at which the proceeds of crime are most apparent and most easily detected.

    Layering Stage: once the money has been placed in the financial system, the launderer engages in a series of conversions or movements of the funds to distance them from the source. For instance, the launderer might transfer the funds to a series of bank accounts situated in different jurisdictions.

    Integration Stage:the launderer would then integrate the funds by investing such funds into, for instance real estate, luxury goods, or business ventures thereby enabling the funds to enter the economy in a legitimate manner.

    4.1.2 Funding of Terrorism

    Regulators in each jurisdiction that Vista operates will provide the local definition as per their regulation. For the purpose of this group Policy, the following definitions are outlined below:

    Terrorism is the use or threat of action designed to influence government or to intimidate any section of the public, or to advance a political, religious or ideological cause where the action would involve violence, threats to health and safety, damage to property or disruption of electronic system.

    Funding of Terrorism is the process by which terrorist organisation or individual terrorists are funded in order to be able to carry out acts of terrorism. This involves solicitation, collection, possession, acquisition, concealment, conversion, transfer or provision of funds with the intention to support terrorist acts or organisations.

    If Vista carries out a transaction, knowing that the funds or property involved in the transaction are owned or controlled by terrorists or terrorist organisations, or that the transaction is linked to, or likely to be used in, terrorist activity, then Vista may be breaching AML laws of several jurisdictions. Such an offence may exist regardless of whether the funds involved in the transaction were the proceeds of criminal activity or were derived from lawful activity but intended for use in support of terrorism. Regardless of whether the funds in a transaction are related to terrorists, for the purposes of national criminal legislation, relationships with such individuals or Associated Persons could, under certain circumstances expose Vista to certain risks.

    Funds used for the purpose of terrorist financing may come both from legal and illicit sources. The set goal is not to conceal the source of funds, but to conceal both the financing and the nature of the financed activity.

    4.1.2 Impact of Money Laundering on Vista

    Vista’s reputation is the most valuable asset, and it is also difficult one to obtain. Having weak AML controls can:

    • Attract criminal liability, either because firm allows funds from criminal activities to be easily processed, either due to employees having been bribed or because the institution turns a “blind eye” to such activity.
    • Imply regulatory action, with private and/or public fines and reprimands based on the incapability of the firm to manage its affairs properly.
    • Issues related to money laundering would likely diminish the ability of Vista to do business internationally, given reputational and financial damages.

    Senior Management are fully committed to ensure Vista’s AML program are effective, fit for purpose and protects Vista from illegal abuse.

    4.1.3 Proliferation financing

    Proliferation financing is the act of providing funds which are used for the manufacture, acquisition, possession, development, movement, or use of nuclear, radiological, chemical or biological weapons and their means of delivery and related materials, in contravention of national and international laws.

    4.1.4 Common Factors

    Money Laundering, Terrorism Financing and Proliferation financing have a common element: the illegality of the source and/or purpose of the funds. Funds acquired from illicit sources and which are intended for Money Laundering have an inherent illegality, whilst funds for terrorism financing have an illegal purpose – this is one of the main reasons why AML/CTF are bundled together. Employees are reminded that the volume of money laundering is roughly equivalent to the size of the UK economy, and that terrorist attacks are not a distant reality. It is Vista’s ethical duty to do all within its power to prevent money laundering, and, as per the statement, apply zero tolerance policy towards any perceived threat.

    4.2 Governance and regulatory framework

    The relevant applicable laws and regulations in each of the jurisdiction where Vista holds an operating legal entity are outlined.

    Vista also observes global standards coming from international bodies such as the Financial Action Task Force (FATF) and the Joint Money Laundering Steering Group (JMLSG).

    4.2.1 Laws
    UK Laws
    The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
    The MLR 2017 sets out the additional obligations of private sector businesses working in areas of higher money laundering risk.

    They aim to stop criminals using professional services to launder money by requiring professionals to take a risk-based approach.
    Proceeds of Crime Act 2002 (POCA)
    The Proceeds of Crime Act 2002 (“POCA”) sets out the legislative scheme for the recovery of criminal assets with criminal confiscation being the most commonly used power. Confiscation occurs after a conviction has taken place.
    US Laws
    The Bank Secrecy Act (BSA)
    The BSA requires private sector businesses to establish AML programs and take certain actions to detect and report suspicious activities.
    The USA Patriot Act – enforced by FINCEN (Department of the Treasury Bureau)
    The USA Patriot Act sets out the AML regulation under the BSA. The federal laws and regulations to prevent money laundering and terrorist financing. This includes customer identification, suspicious activity reporting, and the implementation of AML compliance programs.
    EU Laws
    The Fourth Laundering Directives (AMLD4)
    The AMLD4 set out the AML requirements which includes customer due diligence (CDD), beneficial ownership identification, and risk assessment.
    The Fifth Laundering Directives (AMLD5)
    The AMLD5 sets out additional measures to enhance AML and counter-terrorism financing efforts.

    It should be noted that the Acts referred above can be, and usually are, complemented with Government issued regulations, which assist on the practical implementation of the obligations derived thereof. For matter of economy, we don’t list all the regulations and/or orders above, however they are, when merits, considered for the purposes of creating, updating and improving the AML/CTF framework.

    4.2.2 AML Law & Criminal Offences

    Key aspect of the AML law and criminal offences is the obligation to (i)be vigilant, (ii)be diligent and (iii) be transparent.


    1. Be alert for suspicious behaviour, suspicious transactions, overly complex transactions and transactions or structures with little economic sense;
    2. Ask the right questions and compare actual answers with reasonable expected behaviour and transaction patterns:
    3. (c) Report any suspicions, any concerns and share knowledge.

    Not complying with this Policy in general, and with the regulations in particular, may attract personal criminal liability; to mitigate this risk, Staff is advised to communicate, or, in case of doubt, use the channels at their disposal.

    4.3 Onboarding and Diligences
    4.3.1 Onboarding

    “Know Your Customer” is a key part of the Onboarding process in the prevention and combat against money laundering, terrorist financing and other financial crimes. Therefore, Vista has established specific processes and controls in order to perform an adequate KYC.

    KYC undertakes the following:

    • to identify and understand the structure of legal entities, update the information required for all customers.
    • Ensure that the customer identification processes are adequate as per requirements
    • Screen customers names against sanctions, PEP lists and adverse media, and
    • Store all relevant documentation for the period established in the relevant jurisdiction.
    4.3.2 KYC and Customer Due Diligence (“CDD”)

    Customer due diligence (“CDD”) refers to the activities performed to understand the customer. The due diligence performed by employees and Associate Persons of Vista consists of integrity assessments and other due diligence on Customers. At onboarding, various factors will be considered, including but not limited to (i) country of residence/address, (ii) type of account, (iii) business nature, (iv) corporate structure, (v) source of funds/source of wealth (when needed), (vii) Sanction lists, and (viii) adverse media.

    Due diligence completed by Vista consists in identifying and confirming the authenticity of the information provided by customers during the onboarding and against those obtained by Vista from public and private databases.

    Collected information allows ongoing monitoring of the customer’s activities to ensure that they are consistent with the information provided.

    Where the customer is a legal entity (such as a company), it is essential to understand the ownership and control structure of the customer to identify any beneficial owner or controlling party.

    4.3.3 When must CDD be applied?

    Vista will apply CDD measures when?

    • There is a suspicious of money laundering, terrorist financing or any other financial crime;
    • Establishing a business relationship;
    • There are doubts regarding the veracity of documents, data or information obtained for the purpose of identification or verification;
    • At the standard CDD periodic review/refresh for the relevant customer in accordance with the level of risk attributed by Vista.

    In all, Vista’s CDD procedures must be fully complied with before dealing with any customer takes place.

    4.3.4 CDD Refresh

    Full reviews of existing customer records are undertaken on a regular basis to ensure that the appropriate level due diligence had been carried out, the documents and information held remain accurate, satisfactory and up to date.

    These reviews are conducted every few years, depending on the requirements set for each contract or type of customer.

    4.3.5 Politically Exposed Person (“PEP”)

    Regulators in each jurisdiction that Vista operates will usually determine what is the definition of a PEP as per their regulations. Although, in general terms, a PEP is defined as an individual who is or had an entrusted with a prominent public function within a specific period, which will be specified by the applicable law in their jurisdiction.

    With the position and influence that they may hold, there is a higher risk of them being involved with bribery and corruption, so PEPs are considered higher risk customers.

    4.3.6 Enhanced Due Diligence (EDD)

    Enhanced due diligence (“EDD”) and enhanced ongoing monitoring will be applied throughout the relationship with Vista.

    EDD is not limited to the below:

    • Taking further steps to be satisfied that the transaction is consistent with the purpose and intended nature of the business relationship;
    • Obtaining additional information on the customer and on the customer’s ultimate beneficial owner
    • Obtaining additional information on the source of funds and source of wealth of the customer, the customer’s beneficial owner and other parties to the transaction;
    • Enquiring further on the reasons for the transaction;
    • Obtaining the approval of senior management for establishing or continuing the business relationship (as it is the case for PEPs);
    • Conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied; and
    • Selecting patterns of transactions that need further examination.
    • eeking additional independent reliable sources to verify information provided by the client.
    4.3.7 Transaction Monitoring

    Vista has processes in place for monitoring, detecting, and analysing suspicious transactions/activities. The monitoring is carried in house via our platform.

    4.3.8 Suspicious activity reporting (SAR)

    All suspicious or unusual transactions with relevant indications of money laundering or terrorist financing must be brought to the attention of the Compliance Manager, who will consider on the need to report such transaction/behaviour to the relevant body.

    Vista will report any activity where it believes or has sufficient grounds for knowing or suspecting that a person or entity is engage in money laundering or terrorist financing.

    Regarding “(tipping off)”, it is strictly forbidden to inform the parties involved of the existence of an investigation that an official reporting has been escalated the appropriate authorities/regulatory body.

    Vista must ensure the highest standard of confidentiality in administering its AML reporting procedures.

    4.3.9 Record Keeping

    All records of transactions, products and services provided, as well as documents related to the processes and controls for the prevention of money laundering and terrorist financing will be kept in accordance with the term of the regulation in force in the relevant jurisdiction in which Vista operates.

    Vista is required to keep evidence and records of due diligence checks made and information held on customers and transactions to demonstrate its compliance with the relevant local regulatory framework. These records may also be required to assist law enforcement agencies with their investigations. Vista has a legal obligation in all of the jurisdictions within which it operates to abide by its record keeping obligations.

    Failure to comply with these requirements will constitute an offence in terms of applicable AML legislation.

    4.4 AML/CTF Training & Awareness

    Vista has an AML/CTF training Programme in place to educate employees and associated persons on the topic. Training is mandatory and delivered at the start of the employment and then annually as part of the compliance training programme.

    The training aims to circulate the legal and regulatory requirements as well as instruct all employees in the prevention, identification, mitigation and reporting illicit acts such as money laundering and terrorist financing, as well as increasing awareness of the procedures and internal controls used within Vista for prevention.

    Additional training & awareness may be provided throughout the years. This might be provided to specific collaborators who hold certain positions that demand in-depth knowledge of the laws, regulations and controls related to money laundering and terrorist financing.

    4.5 Independent Testing and Audit of AML/CTF Framework.

    Vista AML/CTF framework is independently audited by an outsourced professional firm in order to examine and evaluate the adequacy and effectiveness of the policies, controls and procedures in place.

    5 Policy Approval and Responsibilities

    The executive committee are responsible for approving this policy and are ultimately responsible for overseeing its management, procedures and controls, ensuring it complies with Group’s legal and ethical obligations, and that all Vista entities, employees and associated persons comply with it.

    The primary owner of this policy is responsible for the timely review, updating and dissemination of this policy in relevant business areas.

    Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy.

    All staff must remain aware of the requirements relevant to their role and ensure these are adhered to.

    5.1 AdHoc Procedures

    This policy, or any of its subsidiary or complementary documents included in the AML & CTF framework, don’t cover a specific need or upcoming process, the Compliance Manager may, propose Adhoc Procedures, to prevent disruptions to business. However, the Procedures must be included on the relevant portion of AML & CTF framework document as soon as practicably possible and be approved in accordance with the processes established therein.

    Although Vista is not legally obliged to have a Money Laundering Reporting Officer (“MLRO”). Vista Compliance Manager shall perform the duties of MLRO. Vista may, from time to time, appoint other Employees to act as Compliance Manager or as designated employees assisting the Compliance Manager. The Compliance Manager is responsible for implementing and maintaining laundering and anti-funding of terrorism procedures and responding to reports of suspected money laundering or terrorism funding activity.

    6 Raising Concerns

    Vista encourages anyone to raise any concerns about potential, suspected or actual misconduct, criminal infraction, non-compliance with applicable laws, regulations or internal policies.

    All employees have the responsibility to help detect, prevent, and report any non-compliance or suspicion regarding this policy. Any concerns can be raised directly to the document owner or through our Whistleblowing Policy. All investigations are conducted in a confidential, fair, and impartial manner which aims to protect the identity of the whistleblower.

    Vista operates a zero-tolerance approach to retaliation against any whistleblower, and any such retaliation will be considered a violation of this policy, and of the Vista Whistleblowing policy.

    7 Breaches

    Failure to comply with this policy may lead to disciplinary measures, which could result in dismissal for misconduct or gross misconduct, without the prejudice to administrative or criminal sanctions. Disciplinary measures will depend on the circumstances of the violation and will be applied in a manner consistent with Vista’s policies. In addition, employees who violate the law during their employment may be subject to prosecution.

    In the event that an Associated Person fails to comply with any provision in this policy and does not remedy the failure (if such a failure is remediable) within 10 days of such Associated Person being notified in writing of the failure by Vista, then Vista may terminate the business relationship with such Associated Person (including terminating all contracts and agreements in force between Vista and such Associated Person) by means of written notice to such Associated Person, with immediate effect, without need of judicial recourse, and without liability for compensation or damages (whether direct and/or indirect) of any type or nature in favour of such Associated Person.

    Vista may terminate relationships with individuals and organisations working on their behalf if instances of non-compliance with this policy are identified. If you suspect or became aware of a breach, you are obliged to report it, without delay to the policy owner.

    8 Review Period

    This policy will be reviewed annually or sooner if there’s a significant change in situation has taken place or likely to occur. Where changes are made, a revised version will be published. Vista may also issue addenda, guidelines and memoranda from time to time to supplement this, Policy. The latest version of this policy and of any addenda, guidelines and memoranda will always be available on Vista’s internal online system (SuccessFactors, or whichever platform Vista may determine from time to time and are accessible by all Employees. It is the responsibility of Employees and Associated Persons to access these online systems and view the latest version of this Policy and of any addenda, guidelines and memoranda from time to time.

    Appendix 1
    “Red Flags”
    1. Customers or Associated Persons named as a ‘Designated Party’, ‘Specially Designated National (SDN)’ or appearing on other similar lists or sanction laws, or connected to countries identified as non-cooperative by the Financial Action Task Force (FATF) and other similar international organisations and bodies with international efforts against money laundering.
    2. Customers or Associated Persons known or suspected to be a terrorist, or appearing on sanction lists relating to terrorism, or connected to countries or persons that are associated with terrorism.
    3. Customers or Associated Persons who are reluctant to provide to Vista Lease complete information and/or provide insufficient, false, or suspicious information.
    4. Customers or Associated Persons who appear to be acting as an agent for another company or individual but decline or are reluctant to provide information regarding that company or individual.
    5. Customers or Associated Persons, who express concern about, or want to avoid, reporting or record keeping requirements.
    6. Payments made in cash or cash equivalents (such as money orders, or prepaid cash cards). Acceptance of cash as a form of payment by Vista Lease is discouraged. However, if no other option to cash is available, steps must be taken to verify that payment is being received from a valid Customer or Associated Person.
    7. Complex deal structures or payment patterns that reflect no real business purpose.
    8. Requests for payment to be made through an unrelated country to an unrelated third party.
    9. Multiple partial payments from various parties on behalf of a single Customer and/or multiple partial payments from various locations. Also included are “double endorsed” or “third party” checks, where a Customer endorses over to Vista Lease as payment for their invoice a check that was originally made out to the Customer.
    10. Customers or Associated Persons whose address is not a physical site but, for example a P.O Box. With respect to Customers the acceptance of P.O. Boxes as an address is discouraged. However, if no other option to a P.O. Box is available for contractual purposes (for example, in certain Middle Eastern countries it is legal for a company‘s registered office to be registered with a P.O. Box), then a physical site address should also be requested from Customer which address Vista Lease may use to address or serve any correspondence that requires evidence of receipt.
    11. Customers making a funds deposit followed by an immediate request that the money be wired out or transferred to a third party, or to another firm, without any apparent business purpose.
    12. Customers attempt to engage in circular transactions, where a payment to Vista Lease is followed by an attempt to obtain a refund from Vista Lease. (This may occur where for example a Customer pays a significant sum in charges for a Flight, and then exercises his right to cancel his booking and seeks a refund, with a request for the refund to, for example, be sent by wire transfer to an account in the Bahamas).
    13. Customers paying in one form of payment and then requesting a refund of the payment in another form; i.e. paying by credit card and requesting a wire transfer refund.
    14. Requests for payments or refunds after funds have been paid into Vista Lease’s bank account by a third party, particularly if there is a request to return money to a different account or individual to the payer.
    15. Overpayments by a Customer for no apparent reason, then asking for refund.