AML Compliance Solutions

Capgemini Finance Service Ltd Overview

Dedicated to providing robust anti-money laundering policies and services, ensuring compliance and safeguarding financial integrity for our clients at Capgemini Finance Service Ltd.

AML Compliance Services

We provide comprehensive anti-money laundering policies tailored for financial institutions like Capgemini.

Risk Assessment Strategies

Developing effective risk assessment strategies to mitigate money laundering threats and vulnerabilities.

Policy Development Support

Assisting in the creation of robust AML policies to ensure regulatory compliance.

Training and Awareness

Offering training programs to enhance awareness of AML regulations and best practices.

Anti-Money Laundering (AML) Policy

1. Introduction

Capgemini Finance Service Ltd ("the Company") operates in the financial consultancy and advisory space and is committed to upholding the highest standards of business integrity. While the Company is not licensed by the Financial Conduct Authority (FCA) and is not subject to FCA regulations, we recognize the importance of preventing our services from being misused for illicit purposes, including money laundering or terrorism financing.

This AML Policy sets forth the internal procedures and voluntary measures the Company adopts to safeguard its services and maintain transparency.

2. Scope

This policy applies to all employees, contractors, and partners of Capgemini Finance Service Ltd. It covers the Company’s advisory services, including:

• Client onboarding and due diligence

• Monitoring of client activities relevant to financial advice

• Reporting of suspicious activities (if any)

• Record-keeping related to client advisory services

Since Capgemini Finance Service Ltd does not hold client funds, does not execute financial transactions, and does not operate under FCA regulations, the scope of this policy is limited to the advisory aspect of its business.

3. Client Due Diligence (CDD)

Although not required by law due to the non-regulated nature of the Company’s activities, Capgemini Finance Service Ltd voluntarily implements client due diligence (CDD) practices to ensure it engages with legitimate clients.

3.1 Identification and Verification

As part of the voluntary client onboarding process:

• Individuals: Basic personal identification, such as name, address, and contact information, will be collected to ensure the client's legitimacy.

• Corporates/Legal Entities: As part of the client engagement process, the Company may request details about the business entity, such as incorporation documents and contact information, for corporate clients.

3.2 Risk-Based Approach

The Company adopts a simplified risk-based approach to assess clients for potential money laundering or financial crime risks. However, since Capgemini Finance Service Ltd does not handle financial transactions, the focus is on ensuring that clients appear legitimate and that their sources of funds (in cases of investments) are appropriate.

4. Monitoring

Given the advisory nature of Capgemini Finance Service Ltd’s services, ongoing monitoring is limited to ensuring that client engagements align with the agreed-upon consultancy services. Should any unusual client behaviour be observed, the Company reserves the right to reassess the engagement or terminate the advisory relationship.

5. Suspicious Activity Reporting

While the Company is not legally required to report suspicious activity under the Proceeds of Crime Act 2002 or the FCA regulations, it voluntarily implements internal reporting mechanisms. If suspicious activities are identified, such as requests for advice on illicit investment strategies or questionable financial sources, the Company may choose to:

• Terminate the advisory relationship with the client

• Report the incident to relevant authorities at the discretion of the Money Laundering Reporting Officer (MLRO)

6. Record Keeping

Capgemini Finance Service Ltd maintains basic records of client engagements, including contact information, contracts, and advisory documentation. These records are kept for at least three years to ensure transparency and accountability.

7. Voluntary Compliance

Although the FCA does not regulate Capgemini Finance Service Ltd and is not legally bound to implement total AML measures, it voluntarily complies with certain elements of the Money Laundering Regulations 2017 to maintain integrity in its operations. This includes:

• Regular reviews of client engagements

• Basic client due diligence for advisory services

• A risk-based approach to identifying higher-risk clients

8. Employee Training and Awareness

Employees involved in client advisory services receive internal guidance on identifying red flags that may indicate potential money laundering or financial crime activities. This ensures that the advisory team can act appropriately when engaging with clients.

9. Limitations

Capgemini Finance Service Ltd does not provide financial transactions, hold client funds, or engage in any regulated activities under the Financial Conduct Authority. As such, this policy is voluntary and should not be construed as adherence to full regulatory AML obligations.

10. Prohibited Countries for Business Engagements

In compliance with international sanctions and internal policies, Capgemini Finance Service Ltd prohibits business dealings with clients, entities, or financial activities in the following countries:

• Afghanistan

• Belarus

• Central African Republic

• Crimea (Ukraine)

• Cuba

• Democratic Republic of the Congo

• Iran

• Myanmar

• North Korea

• Russia (specific entities)

• South Sudan

• Sudan

• Syria

• Venezuela

• Yemen

• Zimbabwe

This list is updated regularly based on global sanctions and AML regulations.

Contact Us

For inquiries regarding our anti-money laundering policy, please reach out through the form provided.

email: compliance@capgeminifinanceltd.com