Financial Crimes Compliance
As part of our responsibility to ensure the integrity of the markets in which we operate, we require all authorized firms to have systems and controls in place to mitigate the risk that they might be used to commit financial crime.
Managing Bribery and Corruption Risks
All of our financial, commodities and oil & gas traders, partners and customers must satisfy us that they have robust governance, effective risk procedures and adequate internal control mechanisms to manage their financial crime risk. Some firms will also have further obligations placed on them by law.
By using effective systems and controls, our firm can detects, prevents and deters financial crime.
DMH builds and maintains these systems as part of our obligations as a firm that operates within regulated sectors. We are also required to comply with the Anti-Money Laundering Regulations.
The approach that we take involves assessing the risks that our business uses for the purposes of financial crime and mitigating those risks effectively through:
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identifying our customers, partners, suppliers, agents and representatives;
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understanding our relationship with them;
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monitoring the way they use our services to identity anything suspicious.
Our systems are appropriate and proportionate to the nature and scale of our business. There is no 'one size fits all' approach that we adopt. It will vary between large firms and small firms, firms operating in products or areas of high risk, and those offering products to customers where the firm assesses there is less financial crime risk.
Senior management takes clear responsibility for managing financial crime risks and be actively engaged in addressing these risks.
In order to transact with DMH , your firm should:
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have a thorough understanding of its financial crime risks in order to apply proportionate systems and controls
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have an organizational structure that promotes coordination and information sharing across the business
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have appropriate up-to-date policies and procedures in place that can be easily accessed and understood by all staff
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employ staff who have the skills and expertise to do their jobs effectively
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review employees’ competence and take appropriate action to ensure they remain competent for their role
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manage the risk of staff being rewarded for taking unacceptable financial crime risks and
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be able to provide evidence to demonstrate that it has adequate systems and controls to prevent the risk that it might be used to further financial crime
Our firm’s efforts to combat financial crime are always subject to challenge. Senior management ensures that policies and procedures are appropriate and are followed, e.g. having robust internal audit and compliance processes that routinely test the firm’s defenses against specific financial crime threats.