Anti-Money Laundering Policy
Introduction
This policy outlines the regulatory requirements, industry guidelines and our own internal processes in relation to Anti-Money Laundering (AML).
The aim of this policy is to ensure that we have the necessary processes in place to prevent our company and our staff from being exposed to Money Laundering by outlining the potential areas where this may occur and what our regulatory obligations are.
Regulatory References
Proceeds of Crime Act 2002 Money Laundering Regulations 2017 FCA Handbook SYSC 6.3 FCA Handbook SYSC 6.1.1.R
JMLSG Guidance
Definition of Money Laundering
Money Laundering is the process by which criminals attempt to conceal the true ownership of the proceeds of their criminal activities to make it appear as though they have come from legitimate sources.
The Money Laundering Reporting Officer (MLRO)
The designated MLRO is Colin MacArthur and can be contacted on 0800 6 118 118 or colin@homeshield.ltd
Responsibilities of the MLRO
· To act as a control point for procedures, legislation, inspection, reporting, training
· To provide guidance and training to staff on Money Laundering issues
· To retain accurate and thorough records.
Staff Training & Awareness
An overview of anti-money laundering responsibilities is provided to all employees handling financial applications in relation to our credit brokerage services and monetary transactions within the first week of joining the company. On an annual basis all appropriate staff are provided with refresher training to ensure they remain aware of their responsibilities.
Legal Obligations
We acknowledge that the Proceeds of Crime Act 2002 places certain legal requirements on all of our employees. These are:
· It is illegal to assist anyone known or suspected of money laundering
· It is illegal to tip off anyone known or suspected of money laundering
· It is illegal to not report anyone known or suspected of money laundering
All of our employees are trained to ensure that they do not knowingly or unknowingly assist or tip off an individual suspected of money laundering.
All suspicions are reported to the MLRO who will then conduct an investigation to determine whether the suspicion is justified and, if necessary, report this to the National Crime Agency (NCA).
Any instances of non-compliance will be handled via our internal disciplinary procedures and if necessary, reported to the National Crime Agency.
Identifying Risk
Below are indicators of where there could be a potential risk of money laundering and our staff are trained to be vigilant
· Where a customer’s credit application is outside what we would usually expect or is unnecessarily complicated.
· Large cash payments
· Unsubstantiated requests for a refund or cancellations
· We must also pay regard to the size and source of an applicant’s deposit and the size of the transaction they wish to carry out.
Suspicious Transaction/Behaviour
It is every individual member of staff’s responsibility to identify suspicious transactions/behaviour and report them to the MLRO via email using the Suspicious Activity Report Form to report (see over). If any employee is unable to use email this should be handed in person to the MLRO.
Retention of Records
All files, including evidence of verification of identity and transaction information, must be retained for six years after our business relationship has ended. If an investigation is in progress then the records must be retained until the authorities confirm the case has been closed. Records may be retained on paper of electronic medium.