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ANTI-MONEY LAUNDERING POLICY

 

ANTI-MONEY LAUNDERING POLICY AND PROCEDURES of ExFor+ C.I.C.

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Last review date: 11/10/2018

   

Prepared by:  CEO/Director Simon Adams 

 

POLICY STATEMENT:

 

ExFor+ C.I.C. has put into place the following policies; Anti-Money Laundering (ALM) Policy and Procedures adopted by ExFor+ C.I.C. in compliance with The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR). The business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:

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  • The identities of all new and existing clients will be verified to a reasonable level of certainty when required to do so

  • A risk-based approach will be taken to the monitoring of client tax and accounting affairs

  • Any suspicious activity will be reported, and all AML activities recorded

 

All senior management and employees of ExFor+ C.I.C. are required to acknowledge and be familiar with the Policies which are designed to lay down a framework to:

 

  • Prevent ExFor+ C.I.C. from being used, intentionally or unintentionally, by criminal elements for money laundering or financing terrorist activities;

  • Enable ExFor+ C.I.C. to know/understand its customers, clientele, contributors, business associates, and other contacts with which ExFor+ C.I.C. has any financial dealings with (collectively, “Dealing Entities”) and their financial background and source of funds better, which in turn would help it to manage its risks prudently;

  • Put in place appropriate controls for detection and reporting of suspicious activities in accordance with applicable laws, procedures and regulatory guidelines; and

  • Equip employees of ExFor+ C.I.C. with the necessary training and measures to deal with matters concerning KYC/AML procedures and reporting obligations.

  • All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.

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ANTI-MONEY LAUNDERING PROCEDURES FOR EXFOR+ C.I.C.

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1.    CUSTOMER DUE DILIGENCE

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The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients of ExFor+ C.I.C. and the ID verification service (Veri-Tags), Events (VETCON) and IIV (Investors In Veterans) are verified to a reasonable level of certainty. This will include all individual clients, all directors and shareholders with a stake holding of 25% or more of client companies, all partners of client partnerships, and every board member of client charities. Identities will be verified either online or face-to face or by a combination of both. 

The following documentation may be presented by the individual:

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For Civilian Customers:

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In person

 

  • Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided. 

  • An original recent utility bill, or government issued document with the same and address matching those provided by the individual.

  • A selfie of yourself on a clear (White/Beige) background to be attached to your profile page this can be sent to us whilst you are in person with us or via the Veri-Tags uplink.

 

Not in person

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As in person but additionally:

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 Any government issued document that provides the date of birth, NI or Tax number or other such government identifier. 

  • Other forms of identity confirmation, such as evidence of a long standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty. 

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For Service Personnel and Veterans:    

 

In person 

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  • Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided. 

  • present an MOD90, Discharge certificate or proof of service from MOD or Veterans UK via letter with matching address to utility bills, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the individual for some time, may also provide a reasonable level of certainty. 

  • An original recent utility bill, or government issued document with the same and address matching those provided by the individual.

  • A selfie of yourself on a clear (White/Beige) background to be attached to your profile page this can be sent to us whilst you are in person or uploaded via the Veri-Tags upload link.

 

Not in person

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As in person but additionally:

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Any government issued document that provides the date of birth, NI or Tax number or other such government identifier. 

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  • Other forms of identity confirmation, such as evidence of a long standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty. 

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If ExFor+ C.I.C. are unable to verify your identity via any of the above methods, you'll have to sign up for a Veri-Tags account and we will then arrange a suitable date and time for a Skype, FaceTime or a WhatsApp call with you via video link to confirm ID with you.

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If ExFor+ C.I.C. fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested. 

 

2.    RISK ASSESSMENT AND ONGOING MONITORING

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The business shall take a risk-based approach in monitoring the financial activities of its clients. This will be carried out whilst preparing the accounts or tax returns, or conducting any other business with the client.  

The business will actively not accept high-risk clients that are identified as follows: 

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  • Clients with businesses that handle large amount of cash (i.e. involving £15,000 or more, or the sterling equivalent) or complex unusually large transactions.

  • Clients with larger one-off transactions, or a number of transactions carried out by the same customer within a short space of time.

  • Clients with complex business ownership structures with the potential to conceal underlying beneficiaries.

  • Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organised crime or drug production/distribution.

  • Situations where the source of funds cannot be easily verified.

  • Unusual patterns of transactions that have no apparent economic or visible lawful purpose.

  • Money sent to or received from areas known to have high levels of criminality or terrorist activity.

 

The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date or information held evidencing the customer’s identity are kept up to date.

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The following are examples of changes in a client’s situation that may be considered suspicious:

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  • A sudden increase in business from an existing customer;

  • Uncharacteristic transactions which are not in keeping with the customer’s known activities;

  • Peaks of activity at particular locations or at particular times;

  • Unfamiliar or untypical types of customer or transaction.

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Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.

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No action need be taken if there is no cause for suspicion.

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3.    INTERNAL CONTROLS AND COMMUNICATION

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Internal controls and Communication are not applicable as the business only has one employee involved in client compliance and they are also the MLRO. 

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4.     MONITORING AND MANAGING COMPLIANCE

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ExFor+ C.I.C. will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:

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  • client identity verification;

  • reporting suspicious transactions;

  • record keeping.

 

ExFor+ C.I.C. will also monitor any developments in the MLR and the requirements of the MLR supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance. 

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5.    SUSPICIOUS ACTIVITY REPORTING

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A Suspicious Activity Report (SAR) will be made to the National Crime Agency (NCA) as soon as the knowledge or suspicion that criminal proceeds exist arises.

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ExFor+ C.I.C. will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.

Further details on NCA and SARS can be found at http://www.nationalcrimeagency.gov.uk/about-us/what-we-do/economic-crime/ukfiu/how-to-report-sars. 

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6.    RECORD-KEEPING

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Records of all identity checks will be maintained for up to 5 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data or information held in evidence of customer identity are kept up to date.

Copies of any SAR, together with any supporting documentation filed will be maintained for 5 years from the date of filing the SAR.

All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.

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7.    TRAINING

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The training of staff is not applicable as the business only has one employee involved in ML compliance who is also the MLRO. 

All affected employees are provided with training that explains The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, The Proceeds of Crime Act 2002 and section 18 and 21A Terrorism Act 2000, and they these affect the firm, its clients and its employees. 

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All affected employees are trained on their responsibilities in relation to money laundering legislation, and are aware of how to identify and deal with transactions that may involve money laundering.

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