AML Statement

Statement of Compliance

Paxum Bank Limited (the “Bank”) complies with the Proceeds of Crime Act, 2014, and all other applicable anti-money laundering (AML) laws and regulations in the Commonwealth of Dominica. This AML statement outlines the Bank’s approach to preventing financial crime and ensuring compliance with regulatory obligations.

Definition of Money Laundering

Money laundering is the process of disguising the origins of funds derived from illicit activities to make them appear legitimate. It includes the processing of any funds derived from any predicate offence, regardless of whether the funds are ultimately integrated into the financial system. Paxum Bank Limited is committed to detecting, preventing, and reporting money laundering and terrorist financing activities in collaboration with the Financial Intelligence Unit (FIU).

Client Identification and Verification

The Bank implements stringent customer due diligence (CDD) and enhanced due diligence (EDD) measures. Prior to account opening, clients must provide:

For Individuals:

  • Passport ID and number
  • Driver’s license
  • Proof of residential address
  • Professional or financial institution reference letter
  • Screening against World Compliance and Office of Foreign Assets Control (OFAC) databases
  • Certificate of Incorporation and Memorandum & Articles of Association
  • Proof of registered address
  • Identification of beneficial owners and authorized signatories
  • Business license (if applicable)
  • Due diligence checks on directors and principal shareholders

The BANK retains all documentation relied upon for client and corporate verification.

Record Retention

All customer records, including identification documents, account details, business transactions, and related communications, shall be retained for a minimum of seven years following the termination of the client relationship. Records include:

  • Transaction logs
  • Wire transfer records
  • Customer due diligence documentation
  • Suspicious transaction reports

Ongoing Monitoring & Reporting

Transaction Monitoring

Paxum Bank Limited continuously monitors financial transactions to detect suspicious activities by:

  • Reviewing large transactions and wire transfers
  • Identifying unusual transaction patterns
  • Conducting periodic risk assessments on clients
  • Screening transactions against global watchlists

Suspicious Transaction Reporting (STRs)

The Bank is obligated to file Suspicious Transaction Reports (STRs) with the Financial Intelligence Unit (FIU) when transactions exhibit indicators of money laundering, terrorist financing, or other financial crimes. Employees must report all suspicions to the AML Compliance Officer, who will determine if an STR should be filed.

Indicators of suspicious transactions may include:

  • Clients transacting beyond their apparent financial means
  • Transactions inconsistent with the client’s stated business activity
  • Multiple cash deposits or withdrawals below reporting thresholds
  • Unexplained wire transfers to or from high-risk jurisdictions
  • Rapid movement of funds with no apparent legitimate business purpose

Employees must not engage in "tipping off," which refers to informing a client that their transaction is under review or that a report has been filed.

Prohibited Activities

Paxum Bank Limited strictly prohibits:

  • Opening or maintaining anonymous accounts
  • Facilitating transactions involving shell banks
  • Conducting business with unregulated online gambling companies
  • Assisting clients in evading AML regulations
  • Failing to report suspicious transactions
  • Engaging in or facilitating human trafficking
  • Facilitating tax evasion
  • Providing services related to unlicensed money transmission
  • Participating in any illegal financial activities

Any employee found engaging in or facilitating prohibited activities will face disciplinary action, including possible termination and legal prosecution.

Sanctions Compliance

Paxum Bank Limited strictly adheres to sanctions imposed by international bodies such as:

  • The United Nations (UN)
  • The Office of Foreign Assets Control (OFAC)
  • The European Union (EU)
  • The United Kingdom (UK) Sanctions Regime
  • The Financial Intelligence Unit (FIU) of Dominica

The Bank conducts regular screening of clients and transactions against sanctions lists to ensure compliance. Any positive matches are escalated to the AML Compliance Officer for further review. Paxum Bank Limited does not process transactions involving sanctioned individuals, entities, or jurisdictions.

AML Training & Compliance Audits

Staff Training

To ensure awareness and compliance with AML regulations, Paxum Bank Limited conducts semi-annual mandatory AML training for all employees. Training sessions cover:

  • Regulatory requirements and legal obligations
  • Recognizing and reporting suspicious activities
  • Updates on emerging money laundering trends
  • Responsibilities under Paxum Bank’s AML framework

Attendance records of AML training sessions will be maintained for a minimum of seven years.

Independent Audits

Paxum Bank Limited's AML framework is subject to independent external audits at least annually. Audits assess:

  • Effectiveness of AML procedures
  • Adequacy of transaction monitoring systems
  • Compliance with regulatory reporting obligations
  • Overall integrity of the Bank's AML program

Final Provisions

This AML statement has been approved by the Board of Directors of Paxum Bank Limited and will remain in effect until formally amended. The Chief Compliance Officer (CCO) is responsible for overseeing AML compliance, reporting directly to the Board of Directors and Executive Management.

All Paxum Bank employees are required to acknowledge and adhere to this statement. Failure to comply may result in disciplinary action and legal consequences.