Terms & Conditions | Ethics | KYC | AML
- Terms & Conditions
Our Terms & Conditions page strongly recommends clients take legal advice before completing any transaction to proposals put forward to them by Unicorn Blue. We can recommend, take measures to recommend and document our recommendation notices, though the final act of acting on the recommendation rests with the client and their basic common sense to independently check and re-check before actually doing. We operate on the premise that if a client is uncomfortable with our proposals, then either we can arrive at a mutually acceptable proposal or, not pursue any proposals altogether.
- Know Your Customer
Not everybody is selected to become our clients even though we have the skills, and, access to skills and resources to complete the client’s business requirements and resolve their business problems in the minimum amount of time and cost. We build up a picture during the qualification process how willing, or unwilling, a prospective clients is willing to complete forms, questionnaires and follow procedures. Our criteria is best summed up as:
- quality, not quantity
- client attitude, not necessarily client aptitude or project value
- we qualify a prospective client’s commitment to move their businesses from their current state to their desired successful state.
- Anti-Money Laundering
- Adherence to regulations protect businesses and their clients. Unicorn Blue does a mixture of regulated and unregulated work, and the Money Laundering Regulations apply to the regulated aspects only. Consultations involving financing, accounting, introduction to regulated persons such as lawyers and accountants, and, financial institutions that are regulated for securities, investment and banking places a legal responsibility for Unicorn Blue to be compliant.
- We have training in Anti-Money Laundering. In some cases, and depending on the complexity of certain assignments, clients may be asked to have their legal representative complete an Anti-Money Laundering Questionnaire as well as provide evidence of their own AML awareness.
- We use the Basel AML Index from the Basel Institute on Governance when scoping an assignment and structuring our consulting fees.
- Money Laundering Reporting Officer: Costanzo Ferraro is Unicorn Blue’s nominated Money Laundering Reporting Officer under Regulation 21(1)(a) on the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and as referred in Section 331 Proceeds of Crime Act 2002.
As a sub-set to Anti-Money Laundering, we consider the following in our evaluation:
- Restricted Countries: We do not accept enquiries from certain countries listed on:
- the EU Sanctions Map
- Financial Action Task Force (FATF) list (high risk/countries with deficiencies in their AML/CTF regimes)
- EU list of high risk third countries
- EU tax havens list (tax governance shortcomings)
- UK Government’s HM Treasury Current trade sanctions, including arms embargoes and other restrictions website
- US Department of the Treasury’s Sanctions Programs and Country Information website
- United Nations Security Council’s Sanctions Committee website.
- Country Risk Assessment: We use various market intelligence websites to assess the level of risk in a client’s domestic or overseas area of operations.