1. Purpose

To establish a framework to prevent and detect money laundering activities within Jinke Hotel.
To comply with applicable laws and regulations regarding AML.

2. Scope

This policy applies to all employees, contractors, and third-party service providers of Jinke Hotel.

3. Definitions

Money Laundering: The process of making illegally obtained money appear legitimate.
Suspicious Activity: Any activity that raises suspicion about the source of funds or the purpose of transactions.

4. Risk Assessment

Conduct regular assessments to identify and evaluate the risks of money laundering specific to hotel operations, including cash transactions, high-value bookings, and international guests.

5. Customer Due Diligence (CDD)

Implement procedures to verify the identity of guests during check-in.
Collect and maintain records of identification documents, payment methods, and relevant booking information.

6. Reporting Suspicious Activities

Employees must be trained to recognize and report suspicious activities or transactions to the designated AML Compliance Officer.
Establish a clear procedure for internal reporting and for notifying relevant authorities.

7. Training and Awareness

Provide regular AML training to all staff, emphasizing the importance of recognizing suspicious activities and understanding compliance obligations.
Update training materials regularly to reflect changes in legislation or best practices.

8. Record Keeping

Maintain accurate records of all transactions, guest identities, and AML training for a minimum of five years.
Ensure records are easily retrievable for audits and investigations.

9. Monitoring and Review

Regularly review and update the AML policy to reflect changes in laws and hotel operations.
Conduct periodic audits to assess compliance with the AML policy and effectiveness of controls.

10. Compliance Officer

Designate an AML Compliance Officer responsible for overseeing the implementation of this policy, training staff, and liaising with regulatory authorities.

11. Disciplinary Actions

Outline potential disciplinary actions for employees who fail to comply with this policy, which may include termination and legal action.

12. Conclusion

Jinke Hotel is committed to preventing money laundering and ensuring compliance with all applicable laws. This policy will be enforced across all levels of the organization.