${business_name}

ANTI-MONEY LAUNDERING POLCIY

PURPOSE

The aim of this Policy is to ensure that the legal principles introduced by the Proceeds of Crime Act 2002 and Money Laundering Regulations 2003 are upheld and complied with by us and our staff within all areas of the business.

Money laundering is the process in which criminally obtained money or assets are passed though legitimate sources in order to clean them, thereafter leaving them with no obvious links to criminal activity.

OBLIGATIONS

As a business we must take all reasonable steps to ensure that we do not engage or become involved with attempts to money launder.

In doing so we:

• Appoint a Money Laundering Nominated Officer

• Implement and review customer identification procedures in relevant circumstances.

• Maintain adequate records of transactions.

The Money Laundering Nominated Offer is ${officer_name} and they are responsible for:

• Receiving and considering reports of suspicious activity or transactions;

• Reviewing our Anti-Money Laundering Procedures Annually to ascertain if improvement could be made;

• Implementing and enforcing current procedures;

• Arranging and implementing staff training as and when required.

All employees are also subject to the following obligations:

• To follow the anti-money laundering processes;

• To report and suspicious activity to the Money Laundering Nominated Office as soon as possible.

Becoming involved in or failing to report Money Laundering activity may be a criminal offence and you may be prosecuted personally.

RED FLAGS

In order to assist you in understanding the types of things that may represent a risk, we have listed some (non-exhaustive) examples below:

• Customers who appear secretive or appear uncomfortable with providing information upon request;

• Customers who change the information given without apparent good reason

• Substantial cash transaction

• Overpayments without good reason

• Requests for refunds

• Requests for account details which are not part of normal business operations

• Parties from other Jurisdictions

• Parties unable to demonstrate a legitimate source from which the funds derived

• Parties who are unable to pass identity checks.

CUSTOMER CHECKS

The Anti-Money Laundering Regulations provide specific controls in relation to any transactions (or group of transactions) which exceed £8,800.00. As a business however, we must ensure that we apply the same level of vigilance to all transactions.

We conduct checks to ensure that we have satisfied ourselves as to the identity of our customers, their owners (for companies) and any relevant third party.

We therefore will obtain:

1. Photographic identification;

2. Proof of address;

If a Third Party is making a payment to us on behalf of the customer, we must ensure that we know why this is, the source of the funds and establish the third party’s relationship to the customer.

A transaction should not be accepted from an unknown or unverified source.

If anything seems unusual or suspicious, immediately seek input from the Nominated Money Laundering Officer.

HOW TO REPORT

In the event that you become aware of or suspect that Money Laundering activities are occurring, you must report the same to the Nominated Money Laundering Officer immediately if possible but if not, within no more than 24 hours.

If for any reason you deem it not appropriate to report to the Nominated Money Laundering Officer (for example if your suspicion relates to them) you must report to your supervisor.

Your report must be in writing and will include:

• A detailed description of your concerns;

• Full details of the parties you suspect to be involved;

• Full details of all transactions that relate to your suspicion;

• Any other information you are able to provide.

You must not inform anyone else of your suspicion or of your report. Following your report, you will be advised if further steps are needed from you. You must not continue to make any further investigations yourself. If appropriate the Nominated Money Laundering Officer (or another senior member of staff) will report the matter to SOCA for investigation following an initial assessment by them. Any report to SOCA will be made within a timely manner.

Informing anyone you suspect to be involved of your suspicion or of any investigation may result in criminal prosecution.

INFORMATION WE RECORD

In relation to all relevant transactions we will obtain, record and retain for a period of 5 years from the date of the transaction:

• Details of the Transaction

• Receipts

• Cheque details

• Paying-in book entries

• Identity evidence

Details of all report, investigations and decision will also be retained for the same period.