Customer Grievance Policy

Our Customer Grievance Policy aims to provide you (our customer) with an acceptable process of complaint resolution in a reasonable amount of time. Complaints and disputes can be made by contacting us through the channels and platforms stated on our website from time to time.

Our staff will handle complaints and disputes according to their training. We will attempt to provide an initial response within 5 business days of the complaint being received. If a complaint is not resolved to your complete satisfaction within 7 business days, it will be put through our internal dispute resolution (IDR) process.

Whilst a complaint is being managed by our IDR process:

  • All enforcement activities will be placed on hold. This hold will continue for 14 days after the dispute is closed or after we provide our final response to you;
  • Our staff will, if needed, ask further questions to establish all relevant facts and to ensure we understand the issue/s that need to be resolved.
  • We will also provide you with direct contact details to a complaint case manager to enable them to follow up on the complaint; and
  • Our team will contact you with regular updates and ensure that a record of the dispute is updated accurately.

The maximum time that we take to provide you with an initial response will depend on the types of complaint made:

  • If the complaint relates to privacy, we will write to the customer within 7 days to acknowledge the complaint and set out how we will deal with the complaint. We aim to provide you with our final response within 30 days of the complaint being made;
  • If the complaint relates to default notices or notices requesting postponement of enforcement proceedings, we aim to provide you with our final response within 7 days of the complaint being made; or
  • For all other complaints we aim to provide you with a response within 5 days of the complaint being made.

During the IDR process we may attempt to resolve the complaint by providing you with an offer of resolution. If you accept our offer of resolution, the complaint will be closed once we and you agree and/or the agreed resolution is implemented.

If we cannot resolve a complaint within the relevant time frames above, we will provide you with a final response which may include:

  • The final outcome of the complaint at IDR including any offer of resolution;
  • Your right to take their complaint to External Dispute Resolution (EDR); and
  • If available, the contact details of the EDR scheme that you can take your complaint to if they are still dissatisfied with the outcome.

In the event we cannot provide a final response to you within the relevant timeframe we will write to you informing of:

  • the reasons for the delay;
  • your right to take their complaint to EDR; and
  • the contact details of the EDR scheme that you can take your complaint to if they are still dissatisfied with the outcome.

Details of the EDR scheme include those are listed below:

Check contract governing law provision.

If you have any further questions in relation to our Customer Grievance Policy, please contact us by calling ((+95)9669919993) or by sending an email to (info@rent2own.com.mm).

PRIVACY POLICY STATEMENT

This policy applies to all dealings with, information you provide and transactions you enter with Rent 2 Own (Myanmar) Company Limited and associates (as such term is defined by the Myanmar Companies Law 2017) (collectively ‘we’, ‘us’ or ‘our’). 

You agree that we, acting individually or collectively, may perform all acts contemplated under this policy.

Your agreement and acknowledgement of this policy forms a single agreement with, and is incorporated by reference into, all other agreements You enter with us acting individually or collectively. 

We are committed to protecting the personal and financial information we collect and hold about you.

We recognise that any personal and financial information we collect about you will only be collected, held, used or disclosed for the purposes we have collected it for or as allowed under the law (such as under the Anti-Money Laundering Law 2014 and Regulations, the Law Protecting the Privacy and Security of Citizens 2017 or the Financial Institutions Law 2016 and applicable Regulations). It is important to us that you are confident that any personal and financial information we hold about you will be treated in a way which ensures its protection.

Personal and Financial Information

When we refer to personal and financial information, we mean information or an opinion about an identifiable individual, or an individual who is reasonably identifiable. This information may include information or an opinion about you.

The personal and financial information we hold about you may also include credit-related information.

Credit-related information means:

  • credit information, which is information which includes your identity; the type, terms and maximum amount of credit provided to you, including when that credit was provided and when it was repaid; repayment history information (information about whether you meet your repayments on time); default information (including overdue payments); payment information; new arrangement information; details of any serious credit infringements; court proceedings information; personal insolvency information and publicly available information; and
  • credit eligibility information, which is credit reporting information supplied to us by a credit reporting body, and any information that we derive from it.

Collection of Personal and Financial Information

The kinds of personal information we may collect and hold about you may include your name, date of birth, address, email address, marital status, number of dependants, bank account details (including internet banking login details and account numbers), transactional history (e.g. payment history and loan balances), occupation, income details, employer information and any other information we made need to identify you such as your passport, driver’s licence or NRC number.

The main consequences of us not collecting personal information are an inability or delay in being able to identify you, contact you or provide services to you.

We will generally not ask you to disclose sensitive information about yourself, such as your religion or health related information. However, sometimes we may be required to collect or hold sensitive information about you or you may provide unsolicited sensitive information (e.g. if you volunteer information regarding your health). In those circumstances, you consent for us to collect and hold such sensitive information.

Electronic collection

We will collect information from you electronically, for instance through internet browsing, mobile or tablet applications, as well as physically.

We may use a technology called ‘cookies’ to provide you with better and more customised service and with a more effective website and mobile application. A ‘cookie’ is a small text file placed on your computer by our web page server. A cookie can later be retrieved by our webpage servers. Cookies are frequently used on websites and you can choose if and how a cookie will be accepted by configuring your preferences and options in your internet browser.

We or our service providers use cookies for different purposes such as:

  • to allocate a unique number to your internet browsers;
  • to customise our website for you;
  • for statistical and/or behavioural analysis purposes;
  • to identify if you have accessed a third-party website; and
  • for security purposes.

In certain circumstances, data collected from use of cookies, pixels, click re-directs and tag containers may reasonably identify you and/or potentially constitute personal or sensitive information. By using our website or service you consent to our use of cookies, pixels, click re-directs and/or tag containers and the data they may collect or disclose, including to overseas entities.

Purposes of collection of personal information

We collect your personal and credit related information so we can:

  • identify you and conduct appropriate checks on you and/ or any security;
  • understand your requirements and provide you with a product or service;
  • set up, administer and manage our products or services, including the management and administration of underwriting, and obtaining loan or lease assessments and credit reports;
  • assess your eligibility to be provided with products or services and to manage the services we provide to you;
  • manage, train and develop our employees and representatives, and providing continuing employment (in relation to our employees only);
  • managing our relationship with you, including debt collection and litigation;
  • manage complaints and disputes, and report to regulatory authorities and dispute resolution bodies;
  • performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes. This may include matching information we collect against other information held by third parties. (We may also use and disclose de-identified data for these purposes);
  • helping us tailor existing or develop new products, services or offers which may be offered to you, and to help us selectively target promotional offers and opportunities to your needs; and
  • developing or seeking to deliver new ranges of products or services.
  • search and register security interests on registers in the Republic of the Union of Myanmar, such as the Directorate of Investment and Company Administration (DICA).

You must not give us inaccurate or incorrect information or omit to provide us with information as we may not be able to provide you with our services.

Where reasonable and practical we will collect your personal information directly from you. We may also collect your personal information from credit reporting bodies, your bank account providers, our service providers, other credit providers, lead generation businesses, access seekers, finance brokers and third-party social media platforms such as Facebook.

We also collect information when you interact with our website. For more information, please see our website terms of use.

Disclosure of information

We may disclose your personal information to third party service providers we contract with to perform certain functions on our behalf such as:

  • debt collection services;
  • any related bodies corporate and/or associates; and
  • database providers who collect (sometimes through the use of first-party cookies, third-party cookies or other third-party identifiers), hold, use and disclose information in order to assist with identity verification, credit scoring and credit reporting bodies, debt collectors and lead providers.

We may also disclose your information to:

  • any of our related bodies corporate and/or associates;
  • direct marketers (that is, associated businesses that may want to market products or services to you). If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us in any of the ways listed at the end of this policy. If the direct marketing is by email you may also use the unsubscribe function;
  • anyone who represents you or anyone to whom you have consented to the information being disclosed;
  • investors, financiers, banks, agents or advisors or any entity that has an interest in, or is considering acquiring an interest in, our business or your contract;
  • where we are required or permitted to do so by law, such as under the:
  • Anti-Money Laundering Law 2014 and Regulations,
  • the Law Protecting the Privacy and Security of Citizens 2017, and/or
  • the Financial Institutions Law 2016 and applicable Regulations
  • companies that provide information and infrastructure systems to us;
  • lead generation businesses and other credit providers. We may exchange or sell your information (including personal information and credit-related information) to third party lead generation companies or other credit providers who may use that information for any of the purposes for which we can use it. That information may also be disclosed to agents, contractors or advisors of the lead generation business or other credit provider;
  • online third-party messenger applications, such as Facebook messenger, for the purposes of contacting you;
  • social media platforms, such as Facebook, for marketing related purposes;
  • to third parties that assist us to enhance our business performance and/or the scope and quality of our services to you such as:
    • website behaviour analysis providers;
    • interest data, remarketing and network impression reporting providers;
  • customer, product, business or strategic research and development organisations;
  • administration or business management services, consultancy firms, auditors and business management consultants;
  • print/mail/digital service providers;
  • imaging and document management service;
  • search engine optimisation service providers;
  • credit reporting agencies; and
  • to your employer, referees or identity verification services.

The abovementioned recipients may be located overseas and may store your personal information outside of the Republic of the Union of Myanmar, including in the USA, the European Union and Singapore.

We may use cloud storage to store the personal information we hold about you. The cloud storage and the IT servers may be located in or outside the Republic of the Union of Myanmar.

Testimonials

We may publish testimonials, comments or feedback you provide to us on the website, which may contain personal information such as your first name and suburb. If you want to remove your personal information that is being displayed on our website, please send your request to us at the contact details below.

Credit-related information

We may collect and hold credit-related information and exchange this information with credit reporting bodies and other entities.

This credit-related information may be held by us in electronic form on our IT servers and may also be held in paper form. We may use cloud storage to store the credit-related information we hold about you and the IT servers may be located in or outside the Republic of the Union of Myanmar.

When we obtain credit eligibility information from a credit reporting body about you, we may also seek publicly available information and information about any serious credit infringement that you may have committed. We may disclose your credit-related information to entities that provide support functions to us. These entities may be located overseas, including in the USA, the European Union and Singapore.

Credit reporting bodies

Your credit-related information may be exchanged with credit reporting bodies. Credit reporting bodies include credit-related information in reports to assist credit providers assess your creditworthiness, assess your application for products or services and to manage your services.

If you fail to meet your payment obligations in relation to any product or service that we have provided or you have committed a serious financial infringement, then we may disclose this information to a credit reporting body.

Sometimes your credit-related information will be used by credit reporting bodies for the purposes of ‘pre-screening’ credit offers on the request of other credit providers.

You should contact the credit reporting body to advise them if you believe that you may have been a victim of fraud. 

Other data collection

We use information technology tools to improve your user experience of our website, products and services and to better understand your customer behaviour and your devices (such as a device’s IP address (captured and stored only in anonymised form), device screen size, device type (unique device identifiers), browser information and geographic location (country only) .  These features collect data via advertising cookies, code and identifiers.

We will not use this information to identify individual users or to match it with further data on an individual user.

Security of Information

We will take reasonable steps to protect your personal information by storing it in a secure environment. We may store your personal information in paper and electronic form. We will also take reasonable steps to protect any personal information from misuse, loss and unauthorised access, modification or disclosure.

Updating your personal information

It is important to us that the personal information we hold about you is accurate and up to date. During the course of our relationship with you we may ask you to inform us if any of your personal information has changed.

If you wish to make any changes to your personal information, you may contact us. We will generally rely on you to ensure the information we hold about you is accurate or complete.

Access and correction to your information

We will provide you with access to the personal information we hold about you. You may request access to any of the personal information we hold about you at that time by contacting us on the details provided below.  We may charge a fee for our costs of retrieving and supplying the information to you.

Depending on the type of request that you make we may respond to your request immediately, otherwise we usually respond to you within 7 days of receiving your request. We may need to contact other entities to properly investigate your request.

There may be situations where we are not required to provide you with access to your personal information, for example, if the information relates to existing or anticipated legal proceedings, or if your request is frivolous.  An explanation will be provided to you, if we deny you access to the personal and financial information that we hold about you.

If any of the personal information we hold about you is incorrect, inaccurate or out of date you may request that we correct the information by contacting us in any of the ways listed at the end of this policy.  If we refuse to correct personal information, we will provide you with our reasons for not correcting the information.

Using government identifiers

If we collect government identifiers, such as your NRC number or passport number or driver’s licence number, we do not use or disclose this information other than as required or permitted by law. We may use government identifiers to verify your identity when you deal with us.

Business without identifying you

In most circumstances it will be necessary for us to identify you in order to successfully do business, including answering general inquiries about our product or services or current promotional offers, however depending on the circumstances we may in some instances do business with you without you providing us with personal information. However, the extent of the information and services we may be able to provide will be limited.

Complaints

If you are dissatisfied with how we have dealt with your personal information, or you have a complaint, you can contact our complaints officer in any of the ways listed at the end of this policy.

Further information

You may request further information or provide feedback on the way we manage your personal and financial (including credit-related) information by contacting us.

Changes to our privacy policy

We may change this policy from time to time. Any updated versions of this policy will be posted on our website and will be effective from the date of posting.

Contact Details

For privacy related queries, complaints or any other requests, you can contact us using any of the following methods:

Phone number: (+95)9669919993

Email: info@rent2own.com.mm

This policy was last updated 12 January 2021.

ANTI-MONEY LAUNDERING AND COUNTER TERRORISM FINANCING POLICY

Legal Department

Final Last updated: February 2021

Contents

1POLICY STATEMENT 3
2DEFINITIONS 4
3‘STANDARD’ AND ‘ENHANCED’ DUE DILIGENCE 6
4DUE DILIGENCE ON OWNERS OF NON-NATURAL PERSONS 8
5INTERNAL RISK MANAGEMENT AND MONITORING 9
6THIRD PARTY RELIANCE 11
7ANONYMOUS ACCOUNTS FORBIDDEN 11
8RECORD KEEPING 11
9DUTY TO REPORT 12
10AML/CTF EMPLOYEE TRAINING PROGRAM 13

1.    POLICY STATEMENT

Rent 2 Own (R2O) is committed to fully comply with all applicable laws and regulations regarding anti-money laundering and counter terrorism financing (“AML/CTF”).  R2O has adopted and will enforce within its activities the provisions set forth in the Anti-Money Laundering Laws & Regulations in order to prevent and detect money laundering, terrorist financing and other illegal activities.

This Policy Statement is designed to assist all clients and Employees in adhering to R2O’s policy and procedures, which, if followed diligently, are designed to protect themselves, R2O, its Employees, its facilities and its activities from money laundering or other illegal activities.

If R2O, its personnel and/or premises are inadvertently used for money laundering (“ML”), financing of terrorism (“FT”) or other illegal activities, R2O can be subject to potentially serious civil and/or criminal penalties. Therefore, it is imperative that every member, officer, director, and employee (each, an “Employee”) is familiar with and complies with the policy and procedures set forth in this document.

To ensure that the R2O’s policies and procedures are adhered to, R2O shall designate an AML/CTF compliance officer.  R2O also maintains an anti-fraud function specifically tasked to identify suspicious transactions and manage the blacklist of individuals to mitigate the risks associated with such listed individuals becoming clients, Employees or customers of R2O.    The designated compliance officer is responsible for training Employees on matters related to compliance with AML/CTF Laws & Regulations and reporting of infringements (or potential infringements) to senior management of R2O.

As at the date of this policy update, a credit bureau is not operating in the Republic of the Union of Myanmar. 

2.    DEFINITIONS

“AML/CTF Laws & Regulations” means the laws and regulations applicable for the time being in the Republic of the Union of Myanmar, including:

  • AML Act No. 24 / 2015
  • AML Order No.45 / 2019
  • AML Notification No. 1201/2015
  • Counter Terrorism Law No.23,2014
  • Counter Financing of Terrorism Rules dated 11 September Notification No. 1202/2015

“Compliance Officer” means the compliance officer R2O shall designate at a management level.  R2O shall ensure the following powers to the officer appointed:

  • Power to access any documents, records, registers and accounts necessary for the performance of his tasks; and
  • Power to request and access any information, notice, explanation or document from any Employee of R2O.

Counter Financing of Terrorism Laws & Regulations” means the Counter Terrorism Law dated 4 June 2014

(The Pyidaungsu Hluttaw Law) No.23, 2014 and the Counter Financing of Terrorism Rules dated 11 September Notification No. 1202/2015;

“CDD” means customer due diligence;

“Domestic and foreign politically exposed person” means a person who is prominent or has been entrusted with public functions within the country or in any foreign country and family members or close associates of such persons;

“Family Book” or a “Household List” is a document with information (NRC number, date of birth, gender, nationality, occupation, address) on the members of the family or household.  This document is given by MoLIP (Ministry of Labour, Immigration and Population) after the head of the household applies in person for it at the MoLIP Township Office.  The letter must be countersigned by the Ward/Village Administrator and this can be used as a proof of address.

Financing of Terrorism” means dealing with or transferring unlawfully the funds by any means with the intention that they should be used or in the knowledge that they are to be used, in full or in part, directly or indirectly by any terrorist or any terrorist group or concealing, moving abroad or transferring to other’s name an asset knowingly or with reason to know that it is stored or maintained or controlled by a terrorist group or a terrorist or any other person on behalf of them or any attempt, assistance or organizing others to commit any of the aforementioned.

International politically exposed person” means a director, a deputy director, a member of the board of directors and a senior member of an international organization, a member who has the similar position or a person who has been entrusted with such function and family members or close associates of such persons;

“Money laundering” means the commission of any of the following:

  • Conversion or transfer of money and property from the proceeds of crime disguising or concealing the illicit origin of the money or property or of helping any person who is involved in an offence to evade the legal consequences;
  • Acquisition, possession or use of money and property, knowing or having reason to know, at the time of receipt, that such money and property are the proceeds of crime;
  •  Participation in, association with, aiding, abetting, facilitating, managing, counseling or being a member of an organized group to commit or attempt to commit any of the above;
  • The laundering of money and property derived may include:
  • Participating, abetting, supporting, providing, managing, advising and being a member of an organized criminal group by organized criminal group;
  • From offences (such as relating to terrorism and financing of terrorism, trafficking in humans and migrant smuggling,  narcotic drugs and psychotropic substances, trafficking of stolen and other illicit goods, corruption, fraud, counterfeit money or goods, murder or causing grievous bodily harm, kidnapping, illegal restraint and taking hostage, sexual exploitation including sexual exploitation of children; infringement of the Intellectual Property Right, counterfeit goods,  robbery or theft, environmental crime, smuggling, extortion, forgery, to tax evasion and other tax crimes, piracy, terrorism, insider trading to get illicit profits by a person who is the first to know the information by using the said information himself or providing it to another person and market manipulation, any offence punishable with imprisonment for a term of a minimum of one year and above under any existing law of the State,  offences prescribed by the Union Government that are applicable to this Law by notification from time to time, laundering money and property in Myanmar that is derived from committing an offence abroad);

Ward or Village recommendation letter” is the recommendation of the customer’s residency from the ward/village administrator.

3.    ‘STANDARD’ AND ‘ENHANCED’ DUE DILIGENCE

  1. Types of due diligence:

R2O shall conduct the following types of due diligence:

  1. FIRSTLY, conduct ‘Standard’ Due Diligence measures;
    1. SECONDLY, if the customer is NOT identified as low risk, conduct ‘enhanced’ Due Diligence measures consistent with the identified risk, determining the extent of the activities which are unusual or suspicious;
  2. Standard Due Diligence Timing:
    1. Standard Due Diligence measures on the customer shall be conducted before carrying out transactions for a customer, or before opening an account or establishing a relationship;
  3. Enhanced Due Diligence Timing:

Enhanced Due Diligence measures on the customer shall be conducted at each of the following times and situations:

  1. When Standard due diligence procedures determine that the customer is not low risk;
  2. Before carrying out a transaction for a customer with R2O above the threshold amount of USD 15000 or equivalent amount in any currency or as from time to time defined conducted as a single transaction or several connected transactions;
  3. Before carrying out or accepting receipt of a domestic and international wire or electronic transfer for a customer;
  4. When there is doubt about the veracity or adequacy of the customer identification data on record;
  5. When there is suspicion that it is linked to money laundering or terrorist financing; and/or
  6. If the anti-fraud department notifies of fraud, potential fraud or that the individual is blacklisted.
  7. Standard Due Diligence Measures and Process:

Standard due diligence measures and process shall be undertaken as follows:

  1. Collecting the following information for Know-Your-Client purposes:
    1. name in full (including other names);
    1. National Registration Card, Citizen Scrutiny Card, Passport;
    1. Permanent address and contact address;
    1. Date of birth;
    1. Nationality;
    1. Occupation;
    1. Phone number (if any);
    1. Photograph identification;
    1. 2 (two) introducer names and accounts (such as the existing current account).
  2. Collecting the information above using independent and reliable independent sources, documents and data.  Accordingly, Know-Your-Client documentation that must be collected and must include at least the following:
    1. NRC (National Registration Card)
    1. Customer’s photograph
    1. Family Book
    1. Ward / Village Recommendation Letter.
  3. Collecting information on and understanding the purpose and intended nature of the business relationship and the purpose of utilizing the product.
  4. Collecting information on the source of income and expenses with consent to calculate the cash flow statement of each customer.
  5. The sales agents collecting the information and documentation for a client application must do so at a point of sale before the underwriting procedure commences.  This information is entered into the company system and verified by the centralized underwriting team based in the head office in Yangon.
  6. Enhanced Due Diligence Measures:

Enhanced due diligence measures shall be undertaken as follows:

  1. Verify if the customer is acting on behalf of another person, company, organization or legal person;
  2. Obtain information on suspicions such as: customer’s name, the details of any ultimate beneficiary of the transaction which is not the customer;
  3. If a customer or a beneficial owner is suspected of being a ‘domestic and foreign politically exposed person’ or an ‘international politically exposed person’:
  4. Seek prior consent from senior management before establishing or continuing a business relationship;
  5. Take all appropriate measures to identify the wealth and source of funds;
  6. Apply the requirements for all types of politically exposed persons to their family members and close associates.
  7. Utilizing resources such as social media (Viber, Facebook) with consent to obtain independent information to recheck the validity of customer’s information that is provided.

4.    DUE DILIGENCE ON OWNERS OF NON-NATURAL PERSONS

If R2O is conducting due diligence on non-natural persons, R2O shall conduct due diligence on the owners of the customer and take reasonable measures to verify the identity of such persons, based on the following information:

  1. For a legal person:
    1. Identity of the natural persons if any as an ownership interest can be so diversified that there are non-natural persons exercising control of the legal person or arrangement through ownership who ultimately have a controlling ownership;
    1. To the extent that there is doubt under the above sub-article as to whether the person(s) with the controlling owner / owner(s) or where non-natural person exerts control through ownership interests, the identity of the natural persons if a person or arrangement through other means;
    1. Where a non-natural person is identified under the above sub-articles, R2O should identify and verify the identity of the relevant natural person who holds the position of senior managing official.
  2. For non-natural person legal arrangements:
    1. Trusts – the identity of the settlor, the trustee(s), the protector (if any), the beneficiaries or class of beneficiaries, and any ultimate effective control over the trust including through a chain of control/ ownership;
    1. Other types of legal arrangements – the identity of persons in equivalent or similar positions.

5.    INTERNAL RISK MANAGEMENT AND MONITORING

  1. R2O shall adopt, develop and implement internal programs, policies, procedures (as necessary) and controls for the implementation of this policy statement and for managing effectively to mitigate the risks identified.
  2. R2O must monitor the implementation of such policies and controls and enhance them, if necessary. In such policies and controls, the following shall be included:
  3. Customer due diligence measures, ongoing due diligence, monitoring the transactions, reporting obligations and record keeping obligations
  4. Procedures to ensure high standard of integrity of its employees and a system to evaluate the personal, employment and financial history of these employees;
  5.  Ongoing Training Programs for employees to assist with regard to know-your-customer, specific responsibilities of anti-money laundering and countering the financing of terrorism and the transactions which are required to report contained in chapter VIII;
  6.  An independent audit function to check in compliance with and effectiveness of the measures taken action in execution of this Law;
  7. R2O shall identify and assess money laundering and terrorist financing risks that arise from new and existing activities or technologies, including delivery channels, and take necessary action to manage and mitigate such risks
  8.   In the case of new products and delivery channels the risk assessment should take prior to the launch of the new products, business practices or the use of new or developing practices;
  9. R2O shall identify and assess the risks of money laundering and financing of terrorism that may arise in relation to new products, services, business or technologies and take appropriate measures to manage and mitigate such risks;
  10. Transactions shall be closely examined to ensure that they are consistent with their knowledge of their customer, commercial activities and risk profile and if necessary, source of funds;
  11.  R2O shall exercise ongoing customer due diligence measures with respect to each business relationship.
  12. Types of measures to take action shall be determined for each of the requirements contained in this policy.  In this determination, the size of business activities, regions, customers, transactions, products, services and delivery channel and scope, geographic and country coverage of the business activities shall be concluded together with the risk of money laundering and financing of terrorism
  13. R2O processes must:
  14. Apply the policies and controls issued under this Policy Statement on a group-wide basis including all branches and majority owned subsidiaries (if any)
  15. Have information sharing procedures within the financial group for the purposes of carrying out customer due diligence measures and managing the risks of money laundering and financing of terrorism, including procedures to safeguard use of information and sharing.

E.    R2O must monitor for:

  1. All complex, unusual, large transactions or unusual patterns of transactions that have no apparent or visible economic or lawful purpose;
  2. Any business relationship or transaction with a person from or in a country which does not apply sufficient measures to prevent money laundering and financing of terrorism; and

F.    R2O shall examine the background and purposes of transaction or business relationships contained from the above as far as possible, and the findings shall be recorded in writing.

6.    THIRD PARTY RELIANCE

R2O may rely on a third party which has capacity to perform the following elements among the customer due diligence measures:

  • Obtain all information, without delay;
    • Make available identification data and other documents relating to customer due diligence measures without delay if it is requested;
    • Satisfy the maintenance, supervision or monitor and assessment for compliance with the requirements, on behalf of itself;

BUT the identification and verification of the customer is the main duty of R2O.

7.    ANONYMOUS ACCOUNTS FORBIDDEN

R2O shall be prohibited from keeping anonymous accounts or accounts in obviously fictitious names.

8.    RECORD KEEPING

  1. R2O shall maintain records of the following information and ensure that the records and underlying information are readily available to the senior management and other competent authorities and the records should be sufficient for the reconstruction of individual transactions:

(a) Documentation, records obtained through customer due diligence process and documents obtained from scrutiny including accounts of customer or beneficial owner and business correspondence for at least five years after the business relationship has been terminated or the occasional transaction has been carried out;

(b) Records of transactions in both domestic and international, attempted or executed for five years after the transaction has been carried out;

(c) Copies of transaction reports submitted under the Law and other related documents for at least five years after the report was submitted to Senior Management;

(d) Risk assessment and other underlying information after that has completed or has updated for a period exceeding five years;

  1. R2O shall keep documents, data or information collected under this section including data especially relating to money laundering and financing of terrorism, high risk customers and business relationships up-to-date and relevant.

9.    DUTY TO REPORT

  1. R2O employees shall promptly report to its senior management if the amount of transaction of money or property is equal to or exceeds the designated threshold or it has reasonable ground to believe that any money or property is obtained by illegal means or is related to money laundering or financing of terrorism or attempt to do so.
  2. R2O employees shall not disclose any report or relevant information and any measure to any person other than among other Employees, external legal counsel and/or appropriate public authorities.
  3. R2O Employees shall report to senior management any cash transaction in an amount which is equal to or exceeds USD 15,000 by a single transaction or several transactions that appear to be linked.
  4. R2O employees shall carry out the risk assessment of money laundering and financing of terrorism according to the laws applicable in Republic of the Union of Myanmar.  The risk assessment and any underlying evidence and information shall be recorded in writing, be kept up-to-date and be readily available to the relevant authorities.

10. AML/CTF EMPLOYEE TRAINING PROGRAM

  1. As part of the R2O’s AML/CTF program, all Employees are expected to be fully aware of the AML/CTF policy statement and procedures.
  2. Each Employee is required to read and comply with this policy statement and procedures, address concerns to the compliance officer.
  3. To ensure the continued adherence to R2O’s AML/CTF policy statement and procedures, all Employees are required to confirm their awareness of the contents of this document by signing an acknowledgement form annually, or more frequently, as required by the compliance officer.
  4. All Employees are required:
  • at a time specified by the Compliance officer, to undertake training programs on Anti-money laundering policy statement policy and procedures;
  • to get trained in how to recognize and deal with transactions which may be related to money laundering;
  • to timely escalate and report the matter to the Compliance Officer;
  • to get themselves acquainted with AML/CTF Laws & Regulations;
  • to comply with the requirements of all R2O Anti-money laundering policy statement procedures and rules;
  • to prevent, detect and report to the Compliance Officer all potential instances in which R2O or its employees, its facilities or its activities have been or are about to be used for money laundering, terrorist financing and other legal activities;
  • to attend anti-money laundering training sessions, so that all such Employees are aware of their responsibilities under R2O’s policies and procedures; and as affected by current developments with respect to anti-money laundering events.

5. R2O must comply exactly with the directives issued by the senior management.