Our Policies > Anti-Money Laundering Policy

Uptaded on 2025

Effective period 2025-2027

Anti-Money Laundering Policy

HAE Group (HAE), along with all its affiliated entities (the Group), is fully committed to maintaining the highest ethical standards in all its operations.

This strong ethical foundation ensures that the group consistently delivers exceptional performance and value to our directors, officers, employees, agents, clients, and shareholders.

To uphold this commitment, the Group recognises the importance of preventing financial crime, including money laundering and related illicit activities. As part of our dedication to transparency, compliance, and integrity, we have adopted this Anti-Money Laundering (AML) policy for the Group. This policy is designed to safeguard our business from potential exploitation by criminal elements, align with global regulations, and protect the reputation of the Group while fostering a culture of accountability and ethical business conduct across all levels.

Scope

This policy applies to all hae employees, agents, contractors, and third-party partners. It governs all financial transactions, including payments for airline cargo and related services, and requires the implementation of procedures to detect, report, and prevent money laundering.

Legal Framework

The AML policy is developed in accordance with international standards such as the Financial Action Task Force (FATF) recommendations and complies with local anti-money laundering regulations where the GSSA operates. This includes compliance with regulations from authorities such as:

  • The Financial Conduct Authority (FCA), the primary regulator for AML within the UK’s financial sector and HMRC for non-financial entities, including money service business not covered by FCA
  • European Union Authority for Anti-Money Laundering and Counteracting the Financing of Terrorism (AMLA)
  • The United States Department of the Treasury and United States Bank Secrecy Act (BSA)
  • Office of Foreign Assets Control (OFAC) sanctions
  • Local Financial Regulatory Authorities

Responsibilities

Compliance: HAE will appoint a designated person responsible for the implementation, monitoring, and enforcement of the AML policy. This individual will ensure that appropriate measures are in place and that employees are trained.

Employees: All staff must understand and follow the AML policy. Any suspicious activity must be reported to the General Counsel.

Know Your Customer (Kyc)

To mitigate the risk of money laundering, HAE will implement KYC procedures. This includes:

  • Customer Identification: Verifying the identity of new customers before any transactions are processed, using government-issued identification and other relevant documents.
  • Risk Assessment: Classifying customers based on risk factors such as the nature of their business, geographic location, and transaction patterns.
  • Due Diligence: Enhanced due diligence measures will be taken for high-risk customers or those located in countries identified as having high levels of corruption or money laundering risk.

Transaction Monitoring

The Group will monitor transactions for suspicious activities, including:

  • Unusually large transactions: Any payments or transactions that are significantly larger than the norm should be flagged.
  • Irregular payment methods: Monitoring payments made in cash or through unverified third parties.
  • Suspicious behaviour: Any behaviour that raises suspicion about the legitimacy of a transaction, such as reluctance to provide identification or unusual routing of payments.

Reporting Suspicious Activity

Employees are required to report any suspicious activity or transactions to the General Counsel.

The General Counsel will review the report and, if necessary, file a Suspicious Activity Report (SAR) with the appropriate regulatory authorities.

Sanctions Screening

All customers and transactions will be screened against national and international sanctions lists, such as the OFAC sanctions list, EU Sanctions List, and other relevant watchlists. Any transactions involving sanctioned entities or individuals will be immediately blocked, and authorities will be notified.

Record Keeping

The Group will maintain accurate records of customer identification, transaction details, and reports of suspicious activity for a minimum period as required by law (varying in the different areas the group operates in). These records will be accessible for audits by regulatory authorities.

Employee Training

All employees must receive regular training on AML regulations and the Groups policies. Training will cover:

  • How to recognize potential money laundering activities.
  • Procedures for reporting suspicious activity.
  • The importance of compliance with AML regulations and sanctions.

Internal Audits and Reviews

Regular internal audits will be conducted to ensure the AML policy is being effectively implemented. Any deficiencies identified during audits will be addressed immediately, and corrective measures will be taken.

Consequences of Non-Compliance

Any employee or third-party partner found to be in violation of this AML policy will face disciplinary action, up to and including termination of employment or contract. Non- compliance may also lead to legal penalties, including fines or imprisonment, as prescribed by law.

Continuous Improvement

HAE is committed to continuously updating and improving its AML policy in response to changes in regulations, emerging risks, and best practices. The Group General Counsel will review the policy at least annually to ensure it remains effective and up to date.