Fraud Prevention Policy

Strategic Corporate Services Limited (SCS Ltd) – Vanuatu

Strategic Corporate Services Limited (SCS Ltd) is fully committed to the highest standards of fraud prevention. Our Fraud Management Systems are aligned with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) protocols as outlined by the relevant regulatory authorities in Vanuatu and applicable international standards.

Company Procedures

SCS Ltd’s procedures are rooted in a firm commitment to prevent, report, and remediate fraud while fostering a corporate and workplace culture that prioritizes ethics and promotes individual responsibility. Our organization has established comprehensive systems for reporting fraud internally. Externally, incidents of fraud can be reported confidentially by emailing secure@scs.vu. All reported incidents are handled with the utmost confidentiality in accordance with our established Fraud Management Procedures.

Definition of Fraud

Fraud is defined as the intentional deception of a person or organization to gain an advantage, avoid an obligation, or cause loss. SCS Ltd maintains a zero-tolerance approach to fraud. Acts of fraud include but are not limited to deception, bribery, forgery, extortion, corruption, theft, conspiracy, embezzlement, misappropriation, false representation, concealment of material facts, and collusion.

Fraud Prevention

SCS Ltd’s Fraud Prevention measures include but are not limited to:

• Anti-Money Laundering and Counter-Terrorism Financing
• Know Your Customer (KYC)
• Organizational Fraud Management

Anti-Money Laundering and Counter-Terrorism Financing

Money laundering is the process of converting funds derived from illegal activities, including but not limited to fraud, corruption, embezzlement, and terrorism, into legitimate funds or investments. The money laundering process involves three phases:

• Phase 1: Placement. Converting cash into financial instruments such as checks, bank accounts, or high-value goods.
• Phase 2: Layering. Transferring or moving funds among accounts and financial instruments to obscure their origins.
• Phase 3: Integration. Reintroducing funds into the financial system, categorizing them as legitimate.

Know Your Customer (KYC)

Our KYC policy is a control mechanism to prevent the registration of customers involved in illegal activities, including money laundering. SCS Ltd’s verification activities and measures comply with applicable laws and regulations issued by relevant authorities. Our KYC policy is implemented through the following:

• Customer Identification and Verification
• Monitoring of Client Activity
• Record Keeping
• Audits

Customer Identification and Verification

Customer intake procedures at SCS Ltd include the collection of essential information to enable customer identification, such as legal name, residential address, nationality, date and place of birth, and physical appearance. Verification involves checking reliable, independent documentation like Photo IDs.

Monitoring

In addition to gathering information, SCS Ltd continuously monitors the activities of all clients to detect and prevent suspicious transactions. If suspicious activities are detected, internal investigations are triggered to determine the nature and specifics of the flagged transactions.

Record Keeping

Records of all transaction data and information obtained during the customer onboarding process are kept. System logs are stored for 5-7 years in accordance with our internal retention policy.

Audits

Our audit system is designed to identify fraud risks, evaluate their nature and extent, and manage them effectively. Periodic audits ensure that we maintain the expected levels of due diligence and care in terms of our AML/CTF compliance and commitments.

Organizational Fraud Management

At SCS Ltd, it is mandatory to maintain a strong anti-fraud culture. We are committed to preventing fraud within the organization by implementing processes designed to prevent, detect, or respond to any suspicious activity. These processes include:

• Knowing Your Employees
• Fraud Awareness Training for Employees
• Mandatory Vacations
• Job Rotation
• Background Checks for New Hires
• Non-Disclosure Agreements

Please note that our Fraud Prevention Policy may change depending on emerging risks or threats.