Governance & Compliance
Our Philosophy
Ensuring Integrity, Transparency, and Trust
Strict adherence to financial laws and ethical standards that protect investors and uphold institutional accountability.
AML & CTF
Money laundering and terrorist financing are recognized as serious risks to the global investment and financial landscape. In response, the Government of Kuwait, along with the Kuwait Monetary Authority and Capital Markets Authority (CMA), has implemented laws to combat such activities, placing specific obligations on regulated institutions.
As a licensed and operational entity in Kuwait, Sea Global Investments adheres strictly to these legal frameworks. The company considers Kuwaiti regulations fundamental and has integrated them as the minimum compliance benchmark. This ensures that Sea Global’s financial products and investment services are not misused for illicit financial activity or linked to terrorist funding.Legal and Regulatory Framework
The principal Kuwaiti legislations issued in this regard are as follows: The Executive Regulations for the Law on Combating Terrorism Crimes and Its Financing were issued according to Kuwait Cabinet Resolution No. 228, dated 05/02/1440H, corresponding to 01/08/2019G. The guide to executing the implementation mechanism of the Security Council resolutions related to preventing the proliferation of weapons of mass destruction and its financing issued by Royal Decree No. 10130 on 01/03/1439H corresponding to 11/19/2017G and CMA circular No. 6/6/2259/19 dated 20 / 07/1440H corresponding to 3/27/2017G. CMA circular number 6/6/2184/19 dated 18/07/1440 H corresponding to 25/03/2019 G related to indicators of concealing the identity of the true beneficiary.Policy Objectives
The objectives of this Policy are: To prevent use of Sea Global Investments’ products or services for money laundering. To prevent damage to Sea Global Investments’ name and reputation by association with money launderers. To ensure that Sea Global Investments complies with money laundering legislation/regulations wherever it does business.
Policy Scope
Meeting the requirements of this Policy is considered of paramount importance and takes precedence over other commercial aspects of managing our customer relationships.
Policy Application
Sea Global Investments will implement policies and procedures to the standards required by the Kuwait legislation (or to any higher standard required internationally), which will:
Identify and know its customers. Ensure that adequate records are kept and preserved. Provide training for relevant employees to enable them to understand and fulfil their obligations under the Kuwait legislation. Ensure that suspicious transactions are reported to the Compliance Officer, who will determine whether a report should be made to the authorities and the Kuwait Financial Intelligence Unit (FIU). Provide the Compliance Officer with all reasonable access to information that may be of assistance to him/her in carrying his/her duties. Ensure that all necessary controls and communications are in place and are operating effectively to prevent money laundering. This Policy should always be read and operated in conjunction with Sea Global Investment’s detailed AML/CTF and KYC procedures.Policy Ownership
The responsibilities connected with this Policy are:
The overall ownership of this Policy rests with Amwal International Investment K.S.C.P’s Compliance Committee. The day–to-day custodian of the Policy is the Anti-Money Laundering Compliance Officer, who also controls the amendments required to this Policy as a result of changing internal and external requirements. The Anti-Money Laundering Compliance Officer is responsible for ensuring that all employees of Sea Global Investment comply with this Policy.Policy Exemption
No deviations from this Policy are permitted except where formally agreed in advance with the Anti-Money Laundering Compliance Officer at the Head Office, acting in consultation with the Compliance Committee, in a documented special relaxation approved by the General Manager. This must only be considered in exceptional circumstances.
The Significance of Compliance
In addition to the criminal penalties, there is an underlying and essential reputational issue to be considered in relation to compliance, represented by the considerable damage that would affect Sea Global Investment’s name and reputation by involvement in a serious money laundering incident.
Monitoring of Transactions
Procedures were put in place to monitor customers’ transactions. The Compliance Unit generates daily and quarterly reports to achieve this task. Any transaction which does not fit within a customer’s transaction profile should be reviewed by the Anti-Money Laundering Compliance Officer, to determine whether the circumstances give rise to any suspicion of money laundering. An employee should judge a transaction to be suspicious if, in their personal judgment, they know or suspect that the transaction might be connected to any criminal offence or activity as detailed in CMA circular number 6/6/2184/19 dated 18/07/1440 H corresponding to 25/03/2019 G related to indicators of concealing the identity of the true beneficiary.
Suspicious Activity Reporting
Any employee who identifies any activity or transaction which he deems to be suspicious must report that suspicion to the Anti-Money Laundering Compliance Officer, who in his/her turn and after agreeing with the employee’s finding, will report it, through a written Suspicious Transaction Report (STR), to the FIU. STRs should not be discussed with anyone other than the Compliance Committee members, including the customer and other staff members, to avoid the risk of “tipping off”.
Maintaining and Updating Information
Following Kuwait Legislation, Money Laundering information and documents will be stored securely for at least a ten-year period. The information relating to customers (personal details, proof of beneficial ownership, etc.) should be kept up-to-date. The Compliance officer will ensure, from time to time, that detailed and concerted renewal efforts are made.
Staff Training and Communication
The Compliance Committee has to prepare a training program on the methods of controlling financial operations, following the control procedure guide, and with other legal and regulatory texts in force. Ensure an ongoing training of the staff and the participation of the officers responsible for operational control and for training in relevant seminars, workshops, and lectures, so that they may keep abreast of money laundering-fighting methods. Ensure any new material issued by the Authorities regarding combating money laundering and terrorist financing is forwarded to all employees, and training should be conducted if needed.
FATCA & CRS
Sea Global Investments and its Group, in line with all major banking institutions worldwide, comply with the terms and conditions of the Foreign Account Tax Compliance Act (FATCA) regarding tax evasion, which was enacted in March 2010 as part of the Hiring Incentive to Restore Employment Act (HIRE Act 2010).
FATCA generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on withholdable payments. The HIRE Act also contained legislation requiring U.S. persons to report, depending on the value, their foreign financial accounts and foreign assets. Automatic Exchange of financial accounts held by US persons is exchanged based on the Agreement between the Government of the Kingdom of Kuwait and the Government of the United States of America for the Improvement of International Tax Compliance and the Implementation of the Foreign Accounts Tax Compliance Act (FATCA). Sea Global Investments, operating under the Kuwait legislations, complies with the Model 1 intergovernmental agreement.Sea Global Investments began applying FATCA regulations in 2014 and adopted a list of indicators to identify US taxpayer clients such as US citizenship, US residency, US green card, US place of birth, US address, US transfers, and US telephone numbers. For that purpose, Sea Global Investments is applying enhanced due diligence on all accounts and updating the client’s information and forms.
Based on FATCA provisions, Sea Global Investments has the obligation to regularly report the US accounts whether individual or entities, to the Kuwait GAZT. In addition, Sea Global Investments will classify the client as “Recalcitrant Account Holder”, as defined by FATCA, and therefore withhold to the benefit of the US tax authorities as a percentage rate of the client’s proceeds or close the client account when one of the following occurs: Refusal or non-cooperation of the concerned client in providing the requested information and documents within the specified period of time; Existence of a contradiction or inconsistency in the information and documents provided by the concerned client; Sea Global Investments has summarized above its understanding of some of FATCA’s provisions and the measures that it is obliged to take in this regard. However, as Sea Global Investments’ employees are not experts in US taxation, Sea Global Investments kindly advises the concerned clients to refer to the US Internal Revenue Service and/or the experts and specialists that they deem appropriate and to act according to their advice and guidance. Therefore, Sea Global Investments cannot be held liable towards anyone for the understanding summarized above and for the measures that it might be compelled to take in implementation thereof. The present notice should be considered as an integrated part of any agreement governing the relationship between the bank and its customers.CRS (Common Reporting Standards) Sea Global Investments Compliance with CRS
Sea Global Investments and its Group Comply with Standard for Automatic Exchange of Financial Information for Tax Matter or Common reporting standards “CRS” The CRS has been designed by the OECD and G20 countries as a single, global standard to promote tax transparency and effectively tackle cross-border tax evasion. Law # 55 “Automatic exchange of information” been enacted on 27/10/2016 and the OECD Standard for Automatic exchange of information in tax matters, also known as the Common Reporting Standards or CRS. Over 100 jurisdictions have currently committed to the CRS. The CRS imposes an obligation on all financial institutions, such as Sea Global Investments, to report information on accounts held by foreign account holders to the Kuwait GAZT on an annual basis. This information will then be automatically exchanged with the tax authorities of the country where the account holder is tax resident, if both respective countries have mutually agreed to exchange information. The new requirement will concern Sea Global Investment’s customer if he/she/it is a tax resident in a reportable country with which the country where he/she/it has an account has agreed to automatically exchange tax information. In this regard upon account opening or account renewal, Sea Global Investments will be requesting customers to complete the self-certification form in order to collect the required information as to be able to identify the reportable accounts for the purpose of exchange of information for tax purposes with the participating jurisdictions. Moreover, the requested self-certification must be valid, signed and dated and supported with documentary evidence on case by case basis. The yearly reporting will cover client information such as name, address, tax residence, tax identification number, account number, as well as financial information. However, as Sea Global Investments employees are not experts in taxation, Sea Global Investments kindly advise its customers to refer to their financial advisor, tax or legal counsel, an expert or specialists that he/she/deem appropriate and to act according to their advice and guidance. Therefore, Sea Global Investments cannot be held liable towards anyone with respect to the understanding summarized above and to the measures that we might be compelled to take in implementation thereof. The present notice should be considered as an integrated part of any agreement governing the relationship between Sea Global Investments and its customers. Sea Global Investments related documents:CODE OF CONDUCT & ETHICS
The Code of Conduct & Ethics affirms the basic policies of ethical standards for all Sea Global Investments staff. The foundation of the code consists of the following basic standards of business and personal conduct: Honesty and candour in Sea Global Investments activities, including observance of the spirit, as well as the letter, of the law; Avoidance of conflicts between personal interest and the interests of the company, or even the appearance of such conflicts; Respecting and maintaining the confidentiality of information obtained in the course of business; Maintenance of Sea Global Investments reputation and avoidance of activities which might reflect adversely on the company; and Integrity in dealing with the company’s assets. All Sea Global Investments staff must comply with the terms of the Code of Conduct & Ethics distributed to them by the company. Any employee who violates any section of this Code of Conduct is subject to disciplinary action up to and including termination of the employment contract.
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