Meer Money Transfer (Meer)
trades as an International Money Remitter. It is entirely based on the Internet
/ World Wide Web ‘www’ (Internet). The Head Office, based in Putney, London is
the sole trading point and the company accepts no physical cash payments for
transfer.
In this regard Meer Money Transfer is routinely visited and audited by both HM
Revenue and Customs and Barclays Bank plc.
The trading model is to accept business from clients, predominantly drawn from
the Kurdish Communities and remit their funds, on directions, to the
geographical area that straddles several International boundaries known as
‘Kurdistan’.
Meer Money Transfer website is produced in English, Arabic and Kurdish. Clients
access the site by signing in as new customers.
Meer Money following adherence to very strict personal identification
procedures, a client identification number. Whenever a client accesses their
account to transact business this unique identifier is appended to their
transaction.
These procedures prescribed under the Money Laundering Regulations 2007 (MLR)
and the Cross Border Payment Rules ensure that all money can be fully tracked
and accounted for.
When commencing business with Meer documentary evidence is produced in addition
to one (1) official document bearing the customer’s photograph. Meer
photocopies all items produced for new clients and those clients subject to a
periodic and on-going review.
These copies are placed into a hard copy file created for each and every client
of Meer.
For Corporate clients Meer additionally requires copies of their Articles and
Memorandum of Association and Company trading accounts for the previous three
(3) years. Meer routinely meets with and interviews corporate clients to ensure
eligibility to use Meer services.
No transaction can take place for a new private or corporate client without
this procedure being undertaken in its entirety.
All new business is passed to the MLRO for his personal attention before it is
accepted.
The website has several information fields that must all be completed and a
client indicates the personal data of the intended recipient. The client will
then indicate where monies are to be sent. A fee is then levied on the chosen
amount and a client is then required to deposit the money plus fee into any
branch of Barclays Bank plc.
Barclays Bank plc dip sample the trading and AML procedures of Meer.
The money deposited into a Meer account is issued a unique username and code
number, ensuring full transparency and monitoring.
Clients can only access their account, following initial activation, by using a
unique (self-generated) code. In the unlikely event that an existing client
forgets their unique code, the Meer IT Manager is able to automatically
generate a password. This is only provided if the client correctly identifies
themselves using three (3) different KYC pieces of information.
Meer uses the Barclays Bank Internet banking facility and is able to remotely
ensure that the client money has been deposited. At given and suitable times
during a business day Meer will issue instructions to out bankers to remit the
money.
Cash cannot be paid from any credit card and no business is undertaken by Meer
whereby credit is offered to a client.
Meer accepts that not all customers have English as their first language and
operates an enquiry desk telephone line for ‘Customer Assistance’. This
customer enquiry point offers assistance in English, Kurdish and Arabic.
Each and every transaction has an Anti-Money Laundering (AML) declaration which
requires completion. Additionally complying with relevant registration all
transactions have sufficient detail for payments to be tracked. Because of an
in built, minimal security time delay, Meer is not at risk of fraud or theft
because of their unique business model. Money is only paid out to those persons
abroad who have provided their own unique security data and produced
photographic identification documents.
All data obtained from client use of the web / internet is securely stored at
the Meer Headquarters. Computers are backed up hourly, to save data, and the
hard drives are securely locked away each night. The server and hard copy
documents are stored separately. The office itself has many security features
and the building benefits from a very robust alarm system, linked to a private
security system and the Police. Such security ensures business continuity and
enables us to ensure continuity to our business.
Anti-Money Laundering protocols are desk based and Meer has IT structures that
ensure client bio data is screened to comply with EU, Bank of England, HM
Treasury, US OFAC and FinCen promulgated lists of ‘suspect persons’. Meer has a
rigorous ‘dip sampling’ process to ensure complicity with business best
practice. Internal Governance is conducted by the MLRO regularly reviewing
business activity and to ensure a regular financial audit of the company.
Meer adopts a Risk Based approach to the conduct of their business and uses
many factors to ensure a rigorous screening is undertaken of clients’ business
activity and their business patterns.
Annually Meer outsources the responsibility of a company audit.
Meer is registered at the Serious and Organised Crime Agency (SOCA) for the
despatch of ‘Suspicious Activity Reports’ (SARs).
Meer due to its International Business activity and money remitting activity is
applying for a Payment Service Institution (PSI) FSA Licence.
Meer has aspirations to passport into the EU because of the very strong Kurdish
diaspora.
Aspirational passport destinations are:
Germany,
Sweden,
Norway,
Denmark,
Netherlands,
Australia (non EEA) Meer regularly reviews AML protocols and has additional
policy documents for Data Protection, Marketing and Security Issues.
Meer is currently seeking to expand into the pre-paid (front loaded) debit card
market. This product will be supplied to registered Meer clients and will also
be available in Kurdistan. The provision of such a debit card will enable
clients to travel outside of Kurdistan and access other products and services
not currently available to them.
Meer currently retains the services of four (4) independent agents. They all
receive regular AML training and are HMRC registered. If a client attends their
business premises to remit monies the agent assists the client to complete the
on-line process. The agents fee is then a proportion the amount levied by Meer.
Meer has recently engaged the services of an AML Consultant and their systems
and controls have benefited from this inter-action and professional advice.
Frequent meetings with staff and the overview of the AML Consultant enable Meer
to act immediately in the event of any concerns concerning their business
activity.
Staff are engaged at all levels to ensure compliance with Meer Protocols and
they are actively encouraged to report concerns or make suggestions that will
improve business procedures.
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