Good governance is central to our business.
Good governance doesn’t just make for good business, it is also central to protecting our clients and employees. Money laundering and the illicit financing of criminality and terrorism have been identified as major threats by governments around the world. Alongside this, financial crime and tax evasion undermine international financial systems and distort markets.
At LTP we maintain an effective and well-established system of internal controls and robust risk management processes, including pre-trade and post-trade fraud detection systems. Our qualified global compliance teams ensure we comply with all relevant legislation to help us protect our customers and help the fight against money laundering and the financing of terrorism.
Specifically, at LTP we:
Self-assessment
Use self-assessment tools to assess our compliance with our internal controls, risk management processes and applicable regulations. The results of the self-assessments are regularly reviewed by Senior Management and the Board of Directors.
Internal Audit
Maintain a professional Internal Audit function that evaluates the adequacy and effectiveness of internal controls, risk management and governance processes; and their level of compliance with applicable rules and regulations. These internal controls are subject to annual assessments to ensure they remain compliant and applicable to new and prevailing rules.
Training & development
We recognise the importance of training and development to keep abreast of prudential requirements and best practices. Our staff attend various training programmes related to their duties including governance and risk management practices, and anti-money laundering.
Mandatory training
In addition, as part of our induction process, we ensure that employees who are responsible for executing and managing financial transactions undergo mandatory anti-money laundering and compliance training. It is also a requirement for employees with fiduciary duties to complete an annual anti-money laundering refresher course.
Acknowledgment
Have employees qualified with certificates and professional memberships from organisations including the Association of Certified Anti-Money Laundering Specialists (ACAMS) and the International Compliance Association.
KYC, SOW & SOF
In accordance with Know Your Customer (KYC) and Source of Wealth and Source of Funds best practice, and as a condition of our licences we verify the identity and residential address of each of our clients. This requirement is reinforced in our Terms & Conditions. We also undertake checks on client employment and income, ensuring funds deposited are within KYC parameters.
No third-party transactions
We do not receive third party deposits nor make third party withdrawals. All deposits are, where possible, returned to source to prevent facilitating the “layering” of fraudulent proceeds.
Identification technologies
Alongside this, we use innovative document authentication technology and electronic databases to mitigate the risk of identity fraud, including situations involving stolen identity and the use of counterfeit documents. Where necessary, we will use electronic identification methods with publicly available databases, carrying out biometric checks and/or requesting “selfie certs” or video calls to verify a client’s identity.
Regular audit
Finally, we annually engage an independent auditor within the ‘big four’ accounting and auditing firms to evaluate the adequacy and effectiveness of the company’s internal controls, risk management and governance processes, and their level of compliance with applicable rules and regulations. In addition, we carry out regular audits throughout the year to ensure our processes and procedures remain robust and in line with prevailing standards and best practices.