Anti-Money Laundering Policy Statement

The Company has a zero tolerance policy towards Money Laundering and dealing with the proceeds of crime, and we are committed to implementing and enforcing effective systems to counter them. As a Company we pride ourselves in adopting the highest international standards to ensure that our company falls fully in line with the AML required. 

In addition, The Proceeds of Crime Act 2002, The Terrorisms Act 2000, The Sanctions and Anti Money Laundering Act 2018,  The Money Laundering, Terrorist and Transfer of Funds (information on Payer) Regulations 2017, place obligations on the Company and any subsidiaries to establish internal procedures to prevent the use of our services for money laundering.

Currently the Company does not undertake activities requiring licensing under the Money Laundering Regulations but we will continue to actively review the situation to ensure that we do not exceed the thresholds over which we must be licensed.

Who is covered by this policy?

This policy applies to the entire workforce, and the expected standards of our business. In addition we expect any suppliers, Clients and contractors to comply with equivalent principles to those set out in this policy and in our Code of Conduct.

Potentially any one of us could be caught by the money laundering provisions if we suspect money laundering and either become involved with it or do nothing about it.

What is Money Laundering?

Money laundering is the process of changing ‘dirty’ money into ‘clean’ money in order to hide the fact it may have originated from criminal activity. Money Laundering is the term used for a number of offences involving the proceeds of crime or terrorism funds.

Money laundering often happens in 3 steps:

1) Cash is introduced into the financial system by some means (placement)

2) This involves a seemingly innocent financial transaction to disguise the illegal source

(layering)

 3) The final step is the receipt of the wealth from these illicit arrangements (integration)

Sometimes, and this is where the Company is most likely to encounter it, it can simply involve receiving payment for goods or services with “dirty” money – often cash but not always. It also includes possessing or concealing the proceeds of any crime.

Any member of the workforce dealing with transactions involving income for services (or other income) must be alert to the possibility of money-laundering, particularly where:

– Cash is offered by the Client

– Overpayment is received and a refund is made, particularly where a cheque refund is

requested.

– Checking the identity of a new client or supplier is proving difficult

– A new client or supplier is reluctant to provide their details

– There isn’t a genuine reason for using the services provided

– A client / supplier attempts to introduce intermediaries to either protect their identity or hide

they’re involvement?

– A client requests a cash transaction

– The source of the cash is not known or is unusual

• The transaction doesn’t seem normal in the context of the client’s usually purchase
• The size or frequency of the transaction is not consistent with the normal activities of the client
• The pattern of the client’s transactions changes unexpectedly

The Company and its business have implemented procedures for reporting suspicious transactions and, if necessary, making an appropriate suspicious activity report (often shortened to SAR) to the Serious Organised Crime Agency (SOCA).

1. We are alert to the possibility that we may become the subject of an attempt to involve us in a Money Laundering transaction. Accordingly, we maintain procedures for verifying and recording the identity of counter-parties, we will report any suspicious behaviour and will ensure our workforce are properly trained in what to do if they suspect any illegal activity.
2. Details of transaction(s) must be retained for at least 7 years after the end of the business relationship. Examples of that documentation are:

• Documents relating to the financial transactions
• Customer Identity checks

3. If we handle invoices, money transactions, payments or receipts, we will consider each transaction carefully, report any suspicious activity and remain vigilant.
4. Large individual cash payments will be treated with caution. Any cash payment over £10,000 will be declined and the person requested to deposit the cash at their bank or with their solicitor and to make payment by debit or credit card, cheque, banker’s draft or solicitor’s cheque.
5. Any suspicious activity will be reported as soon as you possible by employees to the Board of Directors or, through the Speak-up helpline (No. 0800 297 0110). Anyone who suspects that money laundering is on-going will not disclose any material to anyone that might prejudice any investigation.

The consequences for any of us of committing an offence are potentially very serious. The failure to disclose a suspicion of a case of Money Laundering is a serious offence, and there are only very limited grounds in law for not reporting a suspicion.

Failure to comply with the procedures set out in this policy, including reporting suspicious activity, may lead to disciplinary action being taken in addition to any legal prosecution.

This policy should be read alongside other of the Company’s policies and procedures.