Anti-Money Laundering (AML) Policy

1. Definition of money laundering and terrorist financing;

Money laundering is generally defined as engaging in acts designed to conceal or disguise the true origins of criminally derived proceeds so that the proceeds appear to have derived from legitimate origins or constitute legitimate assets. Generally, money laundering occurs in three stages.

1. Cash first enters the financial system at the “placement” stage, where the cash generated from criminal activities is converted into monetary instruments, such as money orders or deposited into accounts at financial institutions.
2. At the “layering” stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin.
3. At the “integration” stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses.

What are the giveaway signs that money laundering is taking place?

• Large cash payments.
• Multiple small cash payments to meet a single payment obligation.
• Payments or prospective payments from third parties.
• Payments from third parties who are foreign public officials or who are politically exposed persons.
• Payments are made in an unusual or complex way.
• Unsolicited offers of short-term loans of large amounts.
• A series of small payments made from various credit cards.
• The prospective payer wants to pay up-front a larger sum than is required.
• Prospective payers are obstructive, evasive or secretive when asked about their identity.
• Prospective payments from a potentially risky source or a high-risk jurisdiction.

Why Our Policy Is Necessary

The legislation imposes certain duties and obligations on our company where we must set up certain procedures to help identify, report, and ultimately eliminate these crimes. Build Assets for Life and its representatives and employees are obliged to follow this legislation otherwise they may face criminal charges and prosecution. :

The primary UK legislation covering anti-money laundering and counter-financing of terrorism is:

• Proceeds of Crime Act 2002
• Terrorism Act 2000
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• Criminal Finances Act 2017
• Terrorist Asset-Freezing Act 2010
• Anti-terrorism, Crime and Security Act 2001
• Counter-terrorism Act 2008, Schedule 7

Furthermore, we understand our obligations in this area and set out our policy to inform you of the measures we take to achieve our policy aims concerning our business circumstances.

2. Appointed AML Officer

Our Company has designated

Name………… Philipa Oshioz ………………as its Anti-Money Laundering Program Compliance Person (AML Compliance Person), with full responsibility for the firm’s AML Policy.

• They are experienced and their qualifications include;  ………………………………………

Their responsibilities will include:

• Monitoring the company’s compliance with AML obligations,
• Overseeing communication and training for employees,
• Ensuring that the company keeps and maintains all of the required AML records
• Ensuring that reports are filed with the appropriate authority.

• They have full responsibility and authority to enforce the company’s AML program and policy. staff awareness and training.

• risk assessment

• customer due diligence
• reporting suspicious activity
• record-keeping

Regular regulatory reviews and training

Our policies, procedures, and internal controls are created to ensure compliance with all applicable regulations and rules and will be reviewed and updated regularly to ensure appropriate policies, procedures, internal controls, and training are in place to allow for changes in regulations and our business.

Staff Training

All Build Assets for Life employees receive specific training so that they are aware of their responsibilities concerning the relevant legislation. How to spot potential money laundering activity, how to report them, how to carry out due diligence, how to deal with customers concerning AML, and how to comply with data protection legislation and practices.

Our appointed AML Officer will:

• arrange regular training for all relevant workers;
• Arrange for the administration of a brief annual test to ensure that all workers are aware of the legislative requirements and responsibilities
• Provide certificates or notifications following the test.

3. Risk assessment and Monitoring Controls

We take a risk-based approach to our AML policy and procedures. This means we have the following monitoring controls in place to ensure that our policies and procedures are being carried out. We undertake risk assessments to understand our business risk profile.

We look at the risk posed by:

• customers and any beneficial owners.
• financing methods
• Delivery channels, for example, non-face-to-face services
• Geographical areas of operation, including sending money to, from or through high-risk third countries.

We also consider the following factors in assessing the risk such as:

• our sellers or buyers companies, partnerships, or trusts, in particular, are there complex or opaque business ownership structures in place,
• international sellers or buyers
• payments that are made to or received from third parties or overseas accounts

We also take into account the risk from:

• non-face-to-face customers.
• the pattern of customer behaviour.
• sellers or buyers that are not local to the area and where another business, local to them, would be better placed to meet their needs
• individuals in either public positions, locations that carry a higher exposure to the possibility of corruption, or both.

4. Verifying client’s identity 

Build assets for life and make sure that we verify all our customers’ identities by checking they are who they say they are.

To do this we take the customers

• name
• photograph on an official document that confirms their identity
• residential address and date of birth

We may do this by asking for a passport, along with utility bills, bank statements, and other official documents.

Other sources of customer information include the electoral register and information held by credit reference agencies such as Experian and Equifax.

We may also use authorized agencies or verification companies to check the identity and other records.

We also aim to identify the beneficial owner if it applies. This may be because someone else is acting on behalf of another person in a particular transaction, or it may be because we need to establish the ownership structure of a company, partnership, or trust.

If we have any doubts about a customer’s identity, we stop dealing with them

5. Customer due diligence (CDD)

In performing due diligence on individual customers and companies we carry out the following checks.

Identifying the customer and verifying the customer’s identity, address and position in the company on the basis of documents, passport, website, data or information obtained from a reliable and independent source.

Conducting an online search at Companies House to confirm the nature and business of the customer and confirm the identities of any directors;

Identifying, where there is a beneficial owner who is not the customer, the beneficial owner; and taking adequate measures, on a risk-sensitive basis, to verify their identity so that the relevant person is satisfied that they know who the beneficial owner is, including, in the case of a legal person, trust or similar legal arrangement, measures to understand the ownership and control structure of the person, trust or arrangement

Obtaining information on the purpose and intended nature of the business relationship.

We apply these checks on all new customers and on a risk-sensitive basis for existing customers.

Ongoing customer due diligence is also carried out during the life of a business relationship but is always proportionate to the risk of money laundering and terrorist funding, based on knowledge of the customer and regular scrutiny of the transactions involved; 

We report any customer who is suspected of carrying out, or is planning to carry out, a regulated activity and is carrying out money laundering or terrorist financing, or has lied about their identity then this must be reported.

We may also conduct enhanced customer due diligence, which could include any additional documentation, data or information that will confirm the customer’s identity or the source of the funds to be used in our business relationship or transaction

Enhanced diligence is required for example, where perhaps the customer has not been physically present for identification or the customer is a politically exposed person.

6. Suspicious activity reports

Our policy is to make sure any suspicions concerning money laundering activity are disclosed by any employee as soon as possible. The disclosure must be on the same day the employee got the information. Bearing in mind that not making a disclosure may mean that the employee is liable to prosecution;

All reports should be filled out and filed with the appropriate authority.

Disclosure should include: 

• Full details of the people involved.
• Full details of the property involved.
• Full details of the nature of involvement.
• The types of money laundering activity involved.
• The dates of such activities.
• The location of the activities.
• How the activities were undertaken.
• The likely amount of money or assets involved.
• The reasons for the suspicions.

7. Record-keeping requirements

To comply with AML legislation we keep records of all customer due diligence measures carried out, for example,

1. customer identification documents.
2. risk assessments
3. your policies, controls, and procedures
4. training records

Such records may include, daily records of transactions, receipts, and customer correspondence in either original or photocopy or computerized, digital or scanned.

We keep records for five years beginning from the date a business relationship ends, to the date a transaction is completed.