Guildwell applies a risk-based approach to anti-money laundering, counter-terrorist financing, proliferation financing, sanctions compliance and related financial crime controls.
The exact controls applied depend on the legal entity providing the service, the jurisdiction, the client, the products requested, expected activity and the risks presented by the relationship.
Customer due diligence
Before establishing a relationship, the relevant Guildwell entity identifies and verifies the customer, persons acting on its behalf, and beneficial owners or controllers where required.
For companies and other legal arrangements, onboarding includes understanding ownership and control, the purpose and nature of the relationship, expected financial activity, and the source and use of funds where relevant.
Where required information cannot be obtained or verified satisfactorily, Guildwell may decline to establish or continue the relationship or may refuse a transaction.
Risk-based onboarding
Each relationship is assessed according to its circumstances.
Risk factors may include:
- ownership and control
- jurisdictions involved
- counterparties
- products and services requested
- expected transaction activity
- delivery channels
- source of funds or wealth
- sanctions and political exposure
- the structure and purpose of the relationship
Higher-risk relationships are subject to enhanced due diligence.
This may include additional ownership or identity evidence, deeper source of funds or source of wealth review, enhanced screening, additional approvals and more focused ongoing monitoring.
Sanctions, PEPs and adverse information
Clients and relevant connected parties are screened against applicable sanctions and political exposure information and are subject to adverse-information review.
Where a politically exposed person, family member or close associate is identified, additional risk assessment and controls may apply.
PEP status is treated as a risk factor, not as evidence of wrongdoing.
Sanctions and adverse-information results are assessed using relevant identifying information and escalated where necessary under the procedures applicable to the responsible entity.
Ongoing monitoring
Compliance does not end when onboarding is completed.
Customer information, beneficial ownership, expected activity, source information, screening results and risk classification are reviewed throughout the relationship.
Reviews may also be triggered by material changes, including:
- ownership or control
- transaction behaviour
- jurisdiction
- product use
- risk indicators
- sanctions or PEP status
- documentation
- other information relevant to the relationship
Transaction monitoring
Transactions and account activity are monitored according to the nature of the service and the risk profile of the client.
Monitoring is designed to identify activity that is inconsistent with the expected use of the relationship, unusual transaction patterns, sanctions concerns and other financial crime indicators.
Potentially suspicious activity is investigated and escalated to the appropriate compliance function.
Reports are made to the relevant authority where required by applicable law.
Securities and transaction participants
For securities and capital-markets activity, financial crime controls may extend beyond the immediate client.
Depending on the transaction, relevant issuers, funds, investment vehicles, introducers, brokers, custodians, settlement agents and other participants may be subject to proportionate due diligence, screening or verification appropriate to their role and risk.
A party's status as a regulated institution does not automatically remove the need for appropriate due diligence.
For Sparling Financial, securities eligibility requirements and AML requirements are separate controls.
Satisfying an investor-eligibility test does not replace customer identification, verification, risk assessment or ongoing monitoring.
Entity-specific responsibility
Guild Financial in Canada and Sparling Financial in the Cayman Islands remain responsible for the financial crime obligations applicable to their own activities.
Shared technology, personnel, service providers or Group policies do not transfer that responsibility from the entity conducting the relevant activity.
Commercial considerations, fees or transaction timelines do not override AML, sanctions, eligibility or financial crime controls.