Anti-Money Laundering Policy Template
This Anti-Money Laundering 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.
This template has been reviewed in light of 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. This document is also available in the Corporate Folder.
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
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
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.
This document is in open format. Either enter the requisite details in the
highlighted fields or adjust the wording to suit your purposes.
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