This Anti-Money Laundering Policy is designed for a low risk business that
wishes to put in place a general policy in order 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
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
There are three main pieces of legislation that businesses need to be aware
• 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:
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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