Anti-Money Laundering Policy & new Customer's details
V12 Management Ltd (“the Company”) is a UK registered company providing secretarial, accounting and administrative services. The business of the Company is medium risk in relation to money laundering, and in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering, we wish to put in place a clear anti-money laundering policy.
The broad definition of money laundering means that potentially anyone could commit a money laundering offence, this includes all employees of the Company, all temporary staff and contractors.
Our policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the medium risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.
The principal primary legislation is The Proceeds of Crime Act 2002 (POCA), which consolidated, updated and reformed criminal law with regard to money laundering, supplemented by the Terrorism Act 2000 and the Fraud Act 2006. The principal secondary legislation is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019.
Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the UK (Section 327 POCA); entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (Section 328 POCA); and acquiring, using or possessing criminal property (Section 329 POCA).
There are also several secondary offences, failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.
Due diligence is performed on all customers who must provide basic information.
Enhanced Due Diligence
It may be necessary for the Company to carry out enhanced due diligence on certain customers where the customer or a transaction involving the customer appears to be “high risk”. This means that there is a higher level of identification and verification of the customer’s identity required. The following non-exhaustive list of situations may indicate a “high risk”:
If enhanced due diligence is carried out, the Company must:
This may include but is not limited to the following:
Customer details must be collected in accordance with the Data Protection Act 2018. This data can be “processed” as defined under the Data Protection Act 2018 to prevent money laundering and terrorist financing.
Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 7 years from the end of any business relationship with that customer.
In application of our Anti-Money Laundering Policy, I requested you provide personal details and IDs.
We are copying here below your answers to our form for personal identification, in order for you to confirm them and sign for approval.
Leave this empty:
Your legal name
Your email address
Signed by Filippo Giordano
Signed On: 07/28/2022
If you have questions about the contents of this document, you can email the document owner.
Document Name: Anti-Money Laundering Policy & new Customer's details
Agree & Sign