Anti-Money Laundering Policy Template

This Anti-Money Laundering Policy is an EXAMPLE only and is intended to be a starting point for you to implement the requirements set out in the legislation and guidance. This template is designed for a low risk, unregulated business only. It is not intended to be used for a regulated business or by those involved in advising regulated entities, such as accountants. 

This policy is designed for a low risk business that wishes to put in place a general AML policy in order to make staff aware of money laundering and terrorist financing and prevent either taking place. It also considers what to do should any money laundering activity be suspected and the due diligence that businesses should undertake on their customers in light of AML legislation.

Money Laundering is the process of moving illegally acquired cash through financial systems so that it appears to come from a legitimate source. Criminals will try to conceal the origin and true ownership of the proceeds of their activities in order to turn the money from “dirty” to “clean”. It is therefore important that businesses, even low risk ones, have procedures and policies in place to identify and prevent money laundering within their company.

The Proceeds of Crime Act 2002 (POCA), is the primary legislation governing anti-money laundering. POCA applies to everyone but certain issues related to money laundering only apply to those engaged in activities in the “regulated sector”. If you fall within the “regulated sector” you are required to put in place certain anti-money laundering policies, controls and procedures to anticipate and prevent your business being used by criminals to launder money and fund terrorism as well as ensure that the ownership and control of any company, legal arrangement or trust structure of a customer is identified and verified. There is more information on both HMRC and the National Crime Agency’s websites as to which businesses fall within the “regulated” sector and what procedures these businesses must follow.

As the 2019 Regulations prescribe mandatory enhanced due diligence measures when a particular transaction appears to be “high risk”, this template has been updated to include wording to cover these situations, even when a business is otherwise considered “low risk”. This has been done as a matter of good practice. If enhanced due diligence is required, customers may wish to seek independent specialist legal advice.

Note that as the 2019 Regulations widen the scope of “obliged entities” subject to them, this template policy is therefore not suitable for those businesses that engage in platforms related to virtual currencies, those who deal in the art market or handle or issue pre-paid electronic cards. Estate Agents and Lettings Agents should use the AML Policy templates specifically created for them in the Property portfolio of templates.

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