Anti-money Laundering

Global Anti-Money Laundering Policy

Introduction

Rain (collectively, with its affiliates, branches and subsidiaries, the “Company”) has implemented this Anti-Money Laundering Policy and Associated Procedures (collectively, the “AML Policy”) to prevent money laundering and terrorist financing in relation to its business. Rain requires all directors, officers, employees, contractors, and agents (collectively, “Representatives”) to read, understand, and follow this AML Policy in the course of performing services for the Company. Rain also expects vendors and other business partners (collectively, “Business Partners”) to adopt and follow appropriate risk-based compliance standards to prevent money laundering and the financing of terrorism in relation to the services that they perform for Rain. This is a summary of Rain’s AML program and policy.

Our Approach

Rain holds a prohibitive stance towards anyone who breaches laws and regulations relating to Money Laundering, Terrorist Financing, Sanctions, Bribery and Corruption, Tax Evasion and Fraud.

At Rain, we understand that tackling financial crime is the right thing to do, not just because legislation tells us so. Our approach to preventing financial crime seeks to tackle the harm generated, as well as supporting compliance with relevant financial crime legislation and regulation in the jurisdictions in which we operate, along with adopting the relevant guidance and recommendations set out by the Financial Action Task Force. Rain’s approach to compliance with financial crime legislation and regulation considers not only the letter, but also the spirit of applicable laws and regulation.

Financial Crime Program

The cornerstone of our financial crime program is a suite of policies designed to comply with the legal and regulatory requirements relating to Anti-Money Laundering and Counter Terrorist Financing. These policies set the minimum mandatory control requirements, which must be adhered to by all global employees within the Company. 

Rain’s approach to financial crime is built on the following pillars:

• Policies, procedures and system controls (including transaction monitoring) - to ensure that the Company seeks to prevent, identify and address financial crime through our operations, products, services and customers;

• Independent Audit – to continuously assess the effectiveness of our controls;

• Regular risk assessments – to ensure we align and continue to strengthen procedures in line with our inherent risks; this is an ongoing process and the Company will continue to strengthen and adopt our prevention procedures as appropriate;

• Due diligence/Know Your Customer (“KYC”) – to enable us to understand our customers. The following measures are in place in order for Rain to do this: 1) Customer identification and verification and the identification of beneficial owners; 2) Enhanced due diligence conducted on our customers displaying higher risk characteristics; 3) Screening our customers against relevant politically exposed persons (PEP) and terrorist lists;

• Colleague and customer training/awareness – to ensure that everyone understands the role they play in tackling financial crime; and

• MLRO - the MLRO will be the cornerstone of our Financial Crime Program as it is their responsibility to ensure implementation within the Company.

Due Diligence Process

In order to fully understand the risks posed to the Company by customers, we have implemented a KYC process. Rain’s identification and verification process requires the customer to provide reliable, independent source documents, data or information. 

Rain will take the necessary steps to confirm the authenticity of documents and information provided by customers. All legal methods for double-checking identification information will be used and Rain reserves the right to investigate certain customers who have been deemed to be high-risk or suspicious, which may include applying Enhanced Due Diligence measures which will further allow the Company to understand the customer where there are higher-risk traits present.

Customer identification information will be collected, stored, shared and protected strictly in accordance with internal data protection and privacy policies and related regulations.

Money Laundering Reporting Officer (“MLRO”)

An MLRO plays an important role in an organisation's battle against money laundering. Most jurisdictions with an AML regulatory framework require organisations to appoint an MLRO who is in charge of the firm’s AML policy and  financial crime program. 

An MLRO holds a key role in protecting the integrity of the financial system. The officer carrying out this function must make informed decisions as to whether a business is being abused to launder the proceeds of criminal activity or provide financial support to terrorists. If an abuse is found, the MLRO should also alert the authorities.

Within Rain, the MLRO is responsible for developing and enforcing the policies and procedures of our Financial Crime Program. The MLRO is required to report any violations of the AML Program directly to the Board and CEO. In addition, the MLRO is responsible for recording and filing Suspicious Activity Reports (“SAR”)/Suspicious Transaction Reports (“STR”), Currency Transaction Reports (“CTR”) and performing an AML Program audit at least annually, which includes the Business Wide Risk Assessment.

Transaction Monitoring and SAR/STR Reporting

Transaction Monitoring is key to any organisations armoury when it comes to combating money laundering/terrorist financing. Rain employs automated transaction monitoring solutions that assist the Company in building a holistic overview of a customers transaction behaviour; this coupled with the information that we obtain at onboarding helps us understand the customer and whether the overall activity is in-line with expectations.

Rain is also able to analyse data when, for example, a customer is subject to Enhanced Due Diligence measures (i.e. customer transaction history can be analysed via internal data). The MLRO will reserve the right to decide whether further information is required from the customer. 

The MLRO will file a SAR/STR if they know, suspect or have reason to suspect illicit activities have occurred while using Rain products and services. A suspicious transaction is often one that is inconsistent with a customer’s known and legitimate business, personal activities or personal means. We leverage our compliance department, which performs transaction monitoring to help identify unusual patterns of customer activity. The MLRO reviews and investigates suspicious activity to determine if sufficient information has been collected to justify the filing of a SAR/STR.

Risk Assessment

In line with the international standards, Rain has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the risks identified or potential risks that are specific to a jurisdiction in which we operate. This will allow resources to be allocated in the most efficient way.

Employee Training

An employee AML training program is established within Rain. The responsibility falls on the MLRO to create, review and maintain the training material and deliver it to existing employees as well as new employees.

The purpose of the training program shall be to familiarise relevant employees of the Company with the Company’s specific AML/CTF policies and procedures and provide instruction for recognition of suspicious activities. In addition, the MLRO will ensure that employees are trained on the obligation to report suspicious transactions to the MLRO. All employees are required to complete a post training assessment, the results of which are captured and maintained by the MLRO.