Countering the Financing of Terrorism (CFT) Policy

1. Introduction

The **Countering the Financing of Terrorism (CFT) Policy** establishes guidelines and regulatory requirements to prevent financial systems from being exploited to fund terrorist activities. It aligns with international laws and frameworks to detect, prevent, and report transactions that may contribute to terrorism financing.

2. Definition of Terrorism Financing

Terrorism financing involves the provision, collection, or movement of funds intended to support terrorist activities, groups, or individuals. This may include:

• Direct funding of terrorist organizations or individuals.
• Using legitimate businesses, charities, or trade routes to disguise financial flows.
• Transferring money across borders using informal value transfer systems.
• Exploiting financial services for laundering illicit funds for terrorist purposes.

3. Legal and Regulatory Compliance

Our CFT policy aligns with global regulatory standards, including:

• Financial Action Task Force (FATF) Recommendations on CFT.
• United Nations Security Council Resolutions (UNSCRs) related to terrorism financing.
• National CFT laws and anti-terrorism legislation.
• Cross-border cooperation initiatives with financial intelligence units (FIUs).

4. Risk-Based Approach

We adopt a **risk-based approach** to identify and mitigate terrorism financing risks by:

• Conducting **enhanced due diligence (EDD)** on high-risk customers and transactions.
• Applying **sanctions screening** against global terrorist watchlists.
• Monitoring **cross-border transactions** and high-risk jurisdictions.
• Reviewing **suspicious patterns**, such as structuring, rapid movement of funds, or third-party payments.

5. Customer Due Diligence (CDD) and Know Your Customer (KYC)

To prevent misuse of financial systems for terrorism financing, financial institutions and businesses must:

• Verify customer identities before establishing relationships.
• Assess the nature of customer activities and funding sources.
• Monitor and report unusual transactions to authorities.
• Ensure ongoing compliance with CFT policies through training and internal controls.

6. Reporting and Monitoring

Financial institutions and businesses must promptly report any suspicious activity related to terrorism financing to:

• National Financial Intelligence Units (FIUs).
• Regulatory and law enforcement agencies.
• International bodies combating financial crime.

7. Sanctions and Asset Freezing

Organizations are required to comply with global **sanctions programs** to prevent terrorism financing by:

• Blocking assets of individuals and organizations linked to terrorist activities.
• Prohibiting transactions with sanctioned entities.
• Cooperating with international financial and security authorities.

8. Training and Awareness

Employees must undergo **mandatory CFT training** to recognize potential terrorism financing risks and comply with reporting obligations. Awareness programs focus on:

• Identifying high-risk customers and transactions.
• Understanding global sanctions lists and compliance measures.
• Recognizing red flags associated with terrorism financing schemes.

9. Consequences of Non-Compliance

Failure to comply with CFT regulations may result in:

• Severe financial penalties and fines.
• Revocation of business licenses.
• Criminal prosecution and imprisonment.
• Reputational damage and loss of business trust.

10. Contact Information

For inquiries regarding this CFT Policy, please contact:

support@rubilink.io