Anti-Money Laundering Policy

Internal Controls

We have robust systems, controls and risk assessments covering all business lines.

Money Laundering Reporting Officer (MLRO)

A senior MLRO oversees all AML/CTF activities, policies and procedures.

Risk-Based Approach

We apply a structured risk-based model that is reviewed annually to manage money laundering and terrorist financing risks.

Customer Due Diligence

All client relationships require full:

• Customer identification & verification
• KYC information
• PEP (Politically Exposed Person) background checks
• Enhanced due diligence for higher-risk clients
• Ongoing review and monitoring

Sanctions Screening

We screen all clients against EU, UK and UN sanctions lists, with automated updates and periodic checking.

Suspicious Activity Monitoring

We monitor transactions to identify unusual or suspicious activity and report to the MLRO and the National Crime Agency where required.

Record Keeping

Records are maintained for at least five years following the end of a client relationship.

Counterparty Due Diligence

We follow UK JMLSG guidance and conduct enhanced due diligence on banks and financial counterparties.

Training & Awareness

All staff receive regular AML and financial crime training.

Disciplinary Measures

Any breach of AML policies may result in disciplinary action or criminal prosecution.