Anti-Money Laundering Policy

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 is a general policy to make staff aware of money laundering, prevent money laundering taking place and what to do should any money laundering activity be suspected. This template has been reviewed in light of the Money Laundering and Terrorist Financing (Amendment) Regulations 2019. This document is also available in the Business 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 company.

There are three main pieces of legislation that businesses need to be aware of:

• Proceeds of Crime Act 2002 (POCA)

• Terrorism Act 2000

• 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.

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 transaction appears to be “high risk”, this template has been updated to include wording to cover these situations, even when a business is otherwise not within the remit of a regulated sector and 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 due to the serious civil and criminal penalties that can result from failure to comply.

Note that as the 2019 Regulations widen the scope of “obliged entities” subject to them, this template policy is 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 Anti-Money Laundering Policy contains the following sections:

1. Introduction

2. Scope of Policy

3. What is Money Laundering?

4. Money Laundering Reporting Officer (MLRO)

5. Suspicions of Money Laundering

6. Consideration of the Disclosure by the MLRO

7. Customer Identification and Due Diligence

8. Ongoing Monitoring

9. Data Protection

10. Record Keeping

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