This is a sample policy for organizations to adapt to their operations and controls. It is not a statement of Captain International's current policy or implementation.
The company, group, board, subsidiaries and responsible units mentioned below are illustrative names. Before use, confirm them against the organization's actual structure and applicable laws.
Publication date: 2026-10-02
Version: V1.0 | Sample policy for reference when drafting the “business integrity” section of a sustainability report.
Note: This document is a public policy statement. Detailed internal procedures, risk assessment forms, reporting forms and other internal control documents are not disclosed publicly.
References: Taiwan's Money Laundering Control Act and Counter-Terrorism Financing Act; FATF's Suggested Best Practices for Banks to Combat Trade Based Money Laundering; and relevant Financial Supervisory Commission requirements.
Introductory text for a corporate sustainability policy page
Our company upholds integrity and maintains a comprehensive anti-money laundering management system. We seek to prevent the Group's global supply chain, cross-border trade and international fund transfers from being misused for money laundering, terrorist financing or proliferation financing. This Code is the Group's public policy statement. Drawing on FATF best practices for combating trade-based money laundering and applicable domestic laws, it sets out core principles, organizational responsibilities, counterparty screening, risk monitoring and reporting arrangements. These measures support integrity in governance and our commitment to sustainable operations.
1. Purpose
To uphold the Group's integrity and corporate social responsibility, this Code aims to prevent money laundering, terrorist financing and proliferation financing; address risks associated with global trade and cross-border supply chains; and prevent the Group's operating processes from being misused as a channel for money laundering. In light of the Company's international trade and cross-border payment activities, the Group establishes this policy to identify, assess and continually manage trade-based money laundering (TBML) risks and protect its reputation and sustainable development.
This Code states the Group's foundational commitments and the principles to be followed by directors, managers, all employees, cooperating suppliers and customers.
2. Scope
This Code applies to the Company, its domestic and overseas subsidiaries, and affiliated entities controlled by the Group.
It covers directors, managers and employees, as well as customers, suppliers, agents and business partners that transact with the Group. Covered transactions include domestic and overseas procurement, product sales, cross-border trade, triangular trade, outsourced cooperation, and cross-border receipts and payments.
3. Definitions
3.1 Money laundering: Concealing or disguising the source, nature, location, ownership or other rights relating to proceeds of specified crimes, or converting them into assets that appear legitimate.
3.2 Trade-based money laundering (TBML): Using commercial trade to transfer criminal proceeds or conceal the source of funds, for example by misrepresenting goods prices, quantities or descriptions, falsifying trade documents, or arranging improper triangular trade.
3.3 Terrorist financing: Providing or collecting assets to support terrorist organizations, terrorists or terrorist acts.
3.4 Proliferation financing: Providing assets to support the development, manufacture or acquisition of weapons of mass destruction.
3.5 Customer/supplier due diligence (CDD): Identifying and verifying a counterparty's identity, business background and ultimate beneficial owner when establishing or conducting a business relationship, and assessing related money-laundering risks.
3.6 Enhanced due diligence (EDD): More rigorous identity verification, background checks and transaction-reasonableness reviews for high-risk counterparties or transactions.
3.7 Politically exposed person (PEP): A prominent domestic or foreign political figure, and that person's family members or close associates.
4. Organization and responsibilities
4.1 Board of directors
The Board approves this Code, oversees the effectiveness of the Group's AML risk-management framework, periodically reviews AML risk reports, and includes AML oversight within its integrity-governance responsibilities.
4.2 Senior management
Senior management appoints an AML lead, coordinates implementation, provides adequate resources, and ensures that due diligence, transaction-risk monitoring, internal reporting and training operate in practice. The lead reports the risk position to the Board.
4.3 AML responsible function (legal/compliance or risk management)
- Maintain this Code and periodically review it against domestic laws and FATF best practices for trade-based money laundering.
- Promote customer and supplier risk classification; review suspicious transactions; receive internal reports; and make external reports where required by law.
- Deliver AML training and retain training records.
- Support internal audit, external review and inspections by competent authorities.
4.4 Sales and procurement teams
Before a transaction, conduct counterparty due diligence and assess the transaction's background and commercial rationale. Report unusual indicators through internal channels.
4.5 Finance team
Review receipts and payments, reconcile fund flows with trade documents, monitor unusual cross-border transfers, and report concerns to the AML responsible function.
4.6 Audit function
Independently assess whether AML controls work effectively. Periodically audit due diligence, transaction monitoring and record retention, track corrective actions, and verify that controls continue to operate.
5. Customer and supplier due diligence
5.1 Before establishing a business relationship, conduct baseline due diligence to identify and verify the counterparty, its business activities, place of operation and ultimate beneficial owner.
5.2 Start EDD when higher-risk indicators appear, including a counterparty in a sanctioned or high-risk country or region, a PEP relationship, triangular trade, inconsistent fund and goods flows, or an unusual transaction pattern.
5.3 Keep counterparty information current throughout the relationship and reassess the risk rating when material information changes.
5.4 Screen applicable sanctions and terrorist lists. Do not establish or continue a business relationship with a sanctioned party.
6. Trade transaction risk identification and monitoring
The Company refers to FATF best practices for combating TBML and uses risk screening for transactions across its global supply chain. Indicators of concern include:
- Inconsistent contracts, invoices, packing lists or bills of lading; vague goods descriptions; or materially unusual prices.
- A mismatch between goods and funds routes in triangular trade without a reasonable commercial explanation.
- A request to redirect payment to an unrelated third-party account.
- A transaction size that is clearly inconsistent with the customer's or supplier's business scale.
The Group reviews higher-risk cross-border and third-party payment transactions. A responsible unit manually reviews system alerts and retains the review record.
7. Suspicious transaction reporting
Any employee who reasonably suspects that a transaction involves money laundering, terrorist financing or proliferation financing must report it to the AML responsible function under internal procedures, regardless of the amount. Employees must not privately alert the counterparty.
The AML function investigates each report. If its assessment finds a suspicious transaction, it reports the matter to the competent authority as required by law and retains complete investigation and filing records.
8. Transaction records and document retention
Counterparty identity information, commercial contracts, invoices, logistics documents, payment records, internal reviews and reporting records are retained for at least five years as required by law. A longer statutory period takes precedence. Records must be retrievable for review and inspection.
9. Training
The Group incorporates AML into its business-integrity training program. New employees receive introductory training; existing employees receive training at least annually; and higher-risk roles such as sales, procurement, finance and customs receive additional instruction on TBML cases and risk indicators.
10. Risk assessment and internal audit
The Group conducts an overall AML risk assessment annually. It covers counterparty, country/region, product and transaction risks, with particular attention to cross-border and triangular trade.
Internal audit periodically checks implementation, requires action plans for identified weaknesses and follows them through closure. The Group reviews this Code when laws or international standards change, or when a material change in its operating model affects risk.
11. Confidentiality and discipline
AML reports, investigations and filings are confidential. Anyone with access must protect the information and must not disclose it externally.
Employees who deliberately conceal suspicious activity, help falsify trade documents, disclose reporting information or refuse to cooperate with an investigation may be disciplined under company rules. Matters that may involve criminal liability are referred to judicial authorities.
12. Supplementary provisions
12.1 This Code takes effect after Board approval. The same approval process applies to revisions.
12.2 Matters not addressed here are handled under applicable money-laundering and counter-terrorist-financing laws, competent-authority requirements and FATF best practices for combating TBML.
12.3 This is the public policy statement. Detailed internal procedures, risk assessment forms and reporting forms remain internal control documents and are not publicly disclosed.
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