Anti-Money Laundering Risk Monitoring

In its capacity as external manager, MNK Capital Management Ltd can serve as the appointed Anti-Money Laundering (“AML”) Compliance Officer. We ensure that the funds we manage are compliant with all applicable legal and regulatory requirements, including:

• Laws and Directives regarding the prevention of Money Laundering (“ML”) and Terrorist Financing (“TF”); and
• Latest relevant circulars, directive or amending laws issued by CySEC.

Our AML Compliance Officer services, for the funds under our management, include the following:

• Assume full responsibility before CySEC;
• Development of AML Policy and manual with supporting procedures;
• Development of AML risk scoring methodology and implementing this for risk scoring investors upon submitting their subscription applications and (for existing investors) upon regular KYC verifications;
• Assessment of the economic profile of investors and ensuring whether it is in line to the investment risk-return profile of the managed fund they subscribe to;
• Gathering and review/analyse investor KYC data;
• Development of internal practices, measures, procedures and controls relevant to the prevention of ML and TF;
• Development and establishment of the managed funds and their investors’ Acceptance Policy;
• Preparation of the AMLCO’s Annual Report on the Prevention of Money Laundering and Terrorist Financing;
• Preparation of the Monthly Prevention Statements;
• Responding to any requests and queries from MOKAS and/ or CySEC;
• Conduct of KYC/Due Diligence of prospective investors prior to on-boarding;
• Assisting in the establishment and implementation of relevant Anti-Money Laundering and Anti-Terrorist Financing policies and procedures as per the provisions of the Law and the requirements of CySEC;
• Conduct ad-hoc inspections on AML matters;
• Assist in responding to any CySEC requests and/or notifications and ensure a good working relationship with the regulatory authorities.