Anti-Money Laundering (AML) Policy
Introduction
Responsibilities
– Directors and Leadership: Oversee the implementation of effective AML controls.
– Money Laundering Reporting Officer (MLRO): Responsible for compliance, monitoring risks, and reporting suspicious activities to the National Crime Agency (NCA).
– Employees: Required to follow AML procedures and report any suspicious activity to the MLRO.
Customer Due Diligence (CDD)
The Company conducts appropriate checks to verify the identity of customers and business partners, including:
– Collecting identification documents (e.g., passports, proof of address).
– Conducting enhanced due diligence (EDD) for high-risk individuals or transactions.
Monitoring and Reporting**
– The Company will monitor transactions for unusual or suspicious activity.
– Suspicious Activity Reports (SARs) will be submitted to the NCA by the MLRO, ensuring no “tipping off” occurs.
Record Keeping
The Company retains records of customer identification, transactions, and SARs for a minimum of 5 years to comply with regulatory requirements.
Training
All relevant employees will receive regular AML training to ensure they understand their responsibilities and how to identify and report suspicious activity.
Policy Review
This policy will be reviewed annually or sooner if required by changes in legislation or the Company’s risk profile.
Contact Information
Lock Gate Holding Ltd
Shelton Street
Covent Garden
London
WC2H 9JQ
Email: info@lockgateholding.com
Phone: –
Approved by:
[Management Team], Lock Gate Holding Ltd
Date: [11/07/2024]