The Policy applies primarily to the UK operations and non-UK subsidiaries and branches
Our commitment is to promote best practice along with a high standard of efficient anti-money laundering/combatting terrorism financing procedures. In order to accomplish this task, the Company provides a clear understanding of anti-money laundering legal procedures combined with a strong internal policy which goes beyond the legal scope, enabling our staff to fully implement procedures for checking customer ID, reporting suspicious transactions, record keeping, audit trails.
The Company's AML Compliance Program consists of the following essential elements:
Responsible officers: The appointment of responsible controllers, nominated officers and AML Compliance Officer; with defined key responsibilities targeted at ensuring MLA polies and procedures are adhered
Risk Assessment Management and Continuous monitoring :Identify, access and monitor the risks of money laundering and terrorist financing that are relevant to the business. The Company�s Risk Assessment is updated annually, and when one or more of the following events takes place in the Company (where those events are not already covered in the risk assessment)- offering new services, new locations, accepting payments from new jurisdiction etc.
All new customers are accessed for risk KYC and CDD . The Company performs due diligence on all customers without exception
Suspicious Activity Reports (SARs):Under Part 7 of the Proceeds of Crime Act and Part 3 of the Terrorism Act, businesses in the regulated sectors and their employees are required to disclose information to the National Crime Agency (NCA) in circumstances where they know or suspect, or have reasonable grounds for knowing or suspecting that another person is engaged in money laundering or terrorist financing. There is an internal procedure for escalating suspicious activity.
Internal Audit: The Company conducts annual checks on its compliance with this policy and associated procedures
Record-Keeping: The Company retains all records of the following for a minimum of five years.
Training: All staff and agents connected to the provision of payment services, receive relevant training specific to their roles and a record is maintained of all staff training conducted, with full details