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Morgan & Morgan is committed to the “Know your Client” legislation and policies which includes, employees and suppliers. In addition, we carry out risk identification and mitigation techniques in order to minimize our exposure to money laundering, terrorist financing and proliferation of weapons of mass destruction.
We follow general and particular policies on compliance, in accordance with the standards established by Morgan & Morgan, and in line with the international Due Diligence practices recommended by the International Financial Action Task Force (FATF) and the laws of Panama, Belize, British Virgin Islands, Bahamas and other jurisdictions for the formation of companies, trusts or foundations.
Morgan & Morgan classifies its customers by using the risk-based approach complementing the identification and verification procedures. This process takes place at the beginning of the business relationship and/or during the contact with the client. In the process, we ask our potential client to complete the form to obtain information such as the activity in which he is engaged, source of funds, full name, physical address, purpose of the company or foundation, tax compliance, as well as any necessary information to obtain a risk rating of the client, which at the same time allows us to mitigate the risk and ensure that clients do not use our services to commit illegal acts. The lawyer in charge of the relationship with the client, requests the information and due diligence documents that apply (depending on the jurisdiction) and verifies the information from the legal point of view. Subsequently, this information is sent to the Compliance Department for revision. Compliance Department verifies if the information / documentation provided by the client is complete as well as the names of all participants of the different services. This review is done in well-known data bases (such as World Check and World Compliance) and using the following lists and data bases:
- OFAC
- UN
- Iran Watch
In the event that risks assessment has a high result, an extended due diligence is applied, in accordance with an established policy which requires financial information from the client, references and expansion of the information provided. All high-risk cases are evaluated by the Executive Committee for approval.
As an internal policy, we DO NOT proceed with the incorporation of corporate vehicles, if required information / documentation is not received completely and in accordance with the applicable laws. Likewise, existing corporate vehicles are also monitored based periodically on their risk assessment and during the business relationship.
Our organization has internal procedures to report suspicious transactions to the competent authorities of the jurisdictions where we have presence and also comply with the reports requested in each jurisdiction regarding the AML. Morgan & Morgan prides itself in not being fined or sanctioned in any of the jurisdictions we offer our services for lack of compliance policies and procedures or for lack of information on our clients. We will always look into new modern techniques and software to enhance our capabilities and cooperative constantly with authorities, in several jurisdictions, on creating legislation that will ensure the corporation are used correctly. Our expertise has led us to create a subsidiary, Panama Compliance Services Inc. (PACOM), to help other industries and companies in their efforts to mitigate risks and apply Know Your Client policies.