Ricardo Persaud

SUPERVISION OF FRONT DESK OPERATIONS:
1. Monitor Front Desk Staff (Compliance Clerks) to ensure adherence with established protocols including the Front Desk Operations Manual and the internal Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Policies and Procedures Manual including ensuring that:
- List of red flags indicators are consulted.
- All necessary CDD or EDD forms are filled out and signed by
customers.
- Staff is aware of his/her duties in relation to the Front Desk
- The staff's weaknesses are identified, and necessary training is provided.
2. Ensure that all customers are properly identified through the established Customer Identification Process inclusive of the provision of their identification documents, proof of address and source of gold.

3. Review and approve the onboarding of all new customers according to Front Desk Operations Manual and the AML/CFT) Policy and Procedures Manual. This function will include escalating certain types of medium and high-risk customers to the Senior Compliance Analyst for approval including:
- Foreign Non-Resident Customers
- Politically Exposed Persons (PEPs)
- Customers from High-Risk Jurisdictions.
- Customer without requisite CDD documentation
4. Ensure the development of individual customer profiles (transaction and activity profiles).
5. Ensure relevant Customers are issued with Exception Letters and ensure that adequate follow-up is done.
6. Ensure that the internal monitoring list is maintained and up to date.

KNOW YOUR CUSTOMER AND ENHANCED DUE DILIGENCE FUNCTION:
7. Ensure that Customer Biodata Form is fully completed and approved.
8. Ensure that KYC Profiles are properly maintained.
9. Assist in evaluating and developing client risk profile in compliance with the Anti-Money Laundering legislation.
10. Assign a risk profile to all new customers and continuing customer based on scoring using the CDD Risk Matrix.
11. Performs additional due diligence on medium and high-risk clients identified via the CDD Risk Matrix process. This would also include escalating certain matters to the Senior Compliance Analyst especially where a suspicion is formed under section 16 of the Anti-Money Laundering and Countering the Financing of terrorism Act.
12. Compile and Manage Beneficial Ownership Register and including ascertaining BO information for all Legal Persons and Legal Arrangements via the Commercial Registry.
13. Develop and maintain internal procedures for conducting CDD and EDD including the performance of enhanced due diligence for high-risk clients including:

- Non-Face to Face Customers
- Third Party Transactions
- Transactions where a customer is deceased.
14. Conduct EDD on customers that fail to provide the necessary CDD documents including checking GGMC Database, Open Sources etc.
15. Conduct EDD for all third-party persons acting on behalf of a customer and prepare report on information gathered.
16. Conduct EDD on all customers carrying out gift and payment transactions including ensuring gift and payment transactions form is completed.
17. Evaluate the reliability of clients' provided information by performing extensive research under the guidance of the Senior Compliance Analyst including requesting beneficial ownership information from the Deeds and Commercial Registry, checking GGMC database for licensing information etc. 18. Submits daily listing of all new customers for vetting and approval by the Senior Compliance Analyst.

SANCTIONS SCREENING:
19. This duty includes the following tasks:
- Screening all new customers via the United Nations Sanctions Committee (UNSC) Consolidated List and the OFAC Sanctions Lists before the commencement of any business relationship.
- Screening all customers at intervals, especially when there is an update to the UNSC Consolidated Lists, or any other lists being utilized.
- Escalate reports of positive matches to the Senior Compliance Analyst via the Internal SAR/STR Form
- Ensure that the Front Desk Staff is aware of any updates the UNSC Lists
20. Screen all new customers via the local internal PEP Lists and escalate to the Senior Compliance Analyst where any positive match is made.
21. Maintain statistics of all sanctions screening done.

TRANSACTION MONITORING AND SUSPICIOUS TRANSACTION REPORTING:
22. Prepare monthly Source of Gold Declaration Report for approval by the Senior Compliance Analyst.

23. Review Weekly Front Desk Reports including Gift and Payment Transaction Reports to determine whether any transaction is deemed suspicious and escalate where necessary.
24. Receive and review red-flagged and monitoring lists prepared by the Front Desk and conduct EDD investigations in accordance with international best practices and the national AML legislation to determine whether internal STR/SAR should be filed with the Senior Compliance Analyst.
25. Promptly prepare internal SAR/STRS where a determination is made that the transaction involves money laundering (ML), terrorist financing (TF), proliferation financing (PF) or proceeds of crime.

EDUCATION AND RESEARCH:
26.Keep abreast of all updates to the Financial Action Task Force (FATF)'s 49 Recommendations and Guidance relevant to the gold sector and customer due diligence including Politically Exposed Persons and other High-Risk Customers, Beneficial Ownership and Control Structure and other relevant topics.
27. Keep abreast of all updates to the sanctions lists including the United Nations Security Council (UNSC) Consolidated List and the OFAC Lists.
28. Conduct research and assist Senior Compliance Analyst in developing policies for reporting suspicious activities.
29. Conduct research and maintain list of red flags indicators for reporting suspicious activities.
30. Ensure Front Desk Operations is kept updated in accordance with AML legislative amendments and international best practices.
31. Engage in research and further education in areas that will enhance job function and the Compliance Department including registering with and completing free courses offered by the Association of Certified Anti-Money Laundering Specialists (ACAMS), the FATF E-Learning Platform, the Egmont Center of FIU Excellence & Leadership (ECOFEL) and any other reputable AML/CFT Institution of Choice.
32. Maintain a working knowledge of essential laws and regulations, such as the AML Act and Regulations and their amendments, GGB Act and its amendments and the Guyana Gold Board (Dealers) Regulations.

33. Keep abreast with all publications by the Financial Intelligence Unit, the National Coordination Committee for AML/CFT/CPF and any other regulatory agency or competent authority.
34. Assist in providing training and supervision of compliance clerks.

PUBLIC AWARENESS:
35. Engage with customers on the necessity and importance of submitting relevant CDD documentation.
36. Develop public awareness materials including brochures, pamphlets, and social media content on AML/CFT/CPF related matters for distribution to customers and publication on GGB'S website.

OTHER DUTIES:
37. Assist in the drafting of letters, reports, and memorandums for internal and external recipients.
38. Prepare quarterly declarations' reports for submission to GGMC.
39. Assist in the reviewing and approving of the Bi-Weekly declarations submitted by the compliance clerks in preparation for payment of Royalties and Taxes in the absence of the Senior Compliance Analyst.
40. All other related duties and functions assigned by the Senior Compliance Analyst, Legal Compliance Manager or General Manager as the case maybe.