Know Your Customer (KYC) Framework

Our KYC policy has been formulated in accordance with the guidance provided by the Joint Money Laundering Steering Group (JMLSG). Additionally, it draws upon resources and recommendations from globally recognized standards like the OECD and UN Principles. Transparency International’s Corruption Perception Index, Know Your Country Rating, and Control Risks Corruption Index also contribute to shaping this policy and its associated controls.

 

Policy Against Bribery and Corruption

Our anti-bribery and corruption policy has been developed by referencing materials from esteemed sources including the UK Ministry of Justice and the US Department of Justice guidelines. We have also aligned it with international standards outlined by the OECD and the UN. A comprehensive process was undertaken to meticulously map out Avari’s global exposure to bribery and corruption risks. This policy takes into account our diverse operations, geographic presence, transactional methods, intermediary and counterparty relationships, and more.

 

Sanctions Oversight

Avari’s sanctions policy is fundamentally geared towards ensuring compliance with pertinent legal requirements while establishing a framework for employees to solicit guidance from our compliance and legal departments regarding transactions or potential transactions. We maintain real-time vigilance over modifications in all relevant sanction regimes, encompassing entities such as US OFAC, EU Official Journal, Swiss SECO, and UK HM Treasury, and integrate these changes into our operations on a daily basis.