Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy of Win Thin & Associates and Win Consulting Ltd.


The Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) Policy of Win Thin & Associates  and Win Consulting Ltd (“the Firm”) delineates the stringent standards, principles, and controls we adopt to uphold our full compliance with applicable global and local anti-money laundering laws and regulatory requirements. This policy frames our commitment to preventing, detecting, and reporting money laundering and terrorist financing activities.

Policy Statement

The Firm is committed to maintaining integrity and ethical standards in all our audit and business practices. We expressly prohibit any transactions that facilitate the laundering of proceeds from illegal activities, adopting rigorous measures to guard against our services being used for money laundering, terrorist financing, or related illicit activities.

AML/CFT Program

Our AML/CFT Program comprises:

  1. Risk Assessment: The Firm regularly assesses its exposure to money laundering and terrorist financing risks, ensuring an effective and responsive risk management approach.
  1. AML/CFT Compliance Officer: A dedicated AML/CFT Compliance Officer, chosen based on requisite expertise, is entrusted with the responsibility and authority to oversee and enforce our AML/CFT Program, guaranteeing the Firm’s ongoing compliance.
  1. Client Due Diligence (CDD): We implement comprehensive CDD procedures that involve identity verification of clients, understanding the nature and intent of their activities, and assessing potential risk factors.
  1. Monitoring and Reporting: We monitor all client transactions, particularly substantial or unusual transactions. Our AML/CFT Compliance Officer is tasked with filing Suspicious Activity Reports (SARs) if suspicions of money laundering or terrorist financing arise.
  1. Training and Awareness: All employees are provided Regular training sessions to enhance their understanding of AML/CFT regulations and equip them with the knowledge and skills necessary to implement our AML/CFT procedures effectively.
  1. Record Keeping: The Firm is committed to maintaining accurate and complete records of all transactions and client identifications for a minimum period mandated by law.
  1. Cooperation with Law Enforcement: We ensure complete cooperation with regulatory authorities and law enforcement agencies, responding promptly and thoroughly to all lawful requests and orders.

Sanctions Compliance

The Firm strictly adheres to international sanction laws, regulations, and resolutions. All transactions conducted through our Firm are meticulously screened against global and local sanction lists.

Client Acceptance Policy

Our Firm refuses to provide services to individuals or entities on international sanction lists or those previously convicted of money laundering, terrorist financing, or other financial crimes. Prospective clients undergo rigorous screening and identity verification before their acceptance.

Continuous Improvement

We frequently review and revise our AML/CFT Policy and procedures to reflect evolving regulations, risk scenarios, and business operations.


The Firm implements a zero-tolerance stance towards money laundering and any associated unlawful financial activity. Violations of this policy will result in serious repercussions, including potential termination of employment, disciplinary actions, and legal consequences.

This policy is obligatory reading for all employees, contractors, and third parties engaged in business with the Firm, as we collectively are responsible for inhibiting money laundering activities.

All employees, contractors, and third parties engaged in business with the Firm are required to visit the following links for more information.

AML / CFT Measures

Other useful links