Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy

Purpose
The purpose of this combined Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy is to set out the principles, controls, and responsibilities necessary to prevent R&E Outsourcing from being used for money laundering, terrorist financing, or other financial crimes. This policy ensures compliance with:

• The UK’s Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended).

• The Proceeds of Crime Act 2002 (POCA).

• The Terrorism Act 2000.

• Relevant EU Directives and international best practices.

Scope
This policy applies to:

• All employees (permanent, temporary, and contract).

• Directors and senior management.

• Consultants, contractors, and third-party partners acting on behalf of R&E Outsourcing.

1. Policy Commitment

R&E Outsourcing is committed to:

• Preventing its services from being used to facilitate money laundering or terrorist financing.

• Identifying and reporting suspicious transactions is by legal obligation.

• Maintaining a culture of integrity, transparency, and compliance.

2. Customer Due Diligence (CDD)

• Verify the identity of all clients, partners, and relevant third parties before establishing a business relationship.

• Apply Enhanced Due Diligence (EDD) in higher-risk situations, such as dealing with politically exposed persons (PEPs), high-risk jurisdictions, complex ownership structures, or transactions involving large sums of cash.

• Conduct ongoing monitoring to ensure customer information remains accurate and up to date.

3. Risk Assessment

• Assess AML and CTF risks for all new and existing clients.

• Consider factors such as client profile, country of operation, nature of transactions, and funding sources.

• Categorise clients into low, medium, or high risk, and apply proportionate controls.

• Review and update risk assessments regularly.

4. Record Keeping

• Maintain CDD and transaction records for at least five years after the end of the business relationship.

• Ensure records are accurate, secure, and readily retrievable for regulatory inspection.

5. Monitoring and Reporting

• Monitor transactions for unusual, complex, or suspicious patterns.

• Identify potential indicators of money laundering, such as inconsistent transaction behaviour or unexplained sources of funds.

• Identify potential indicators of terrorist financing, such as small but frequent transfers to high-risk jurisdictions or transactions linked to sanctioned entities.

• Report suspicious activity immediately to the appointed Money Laundering Reporting Officer (MLRO).

• The MLRO will review and, if appropriate, submit a Suspicious Activity Report (SAR) to the UK’s National Crime Agency (NCA).

6. Training and Awareness

• Provide regular AML and CTF training to all employees to ensure awareness of legal obligations, detection methods, and reporting procedures.

• Include case studies and practical examples to improve the identification of suspicious activities.

• Maintain detailed records of training sessions completed.

7. Responsibilities

• Money Laundering Reporting Officer (MLRO) – Oversees AML and CTF compliance, maintains records, and ensures timely reporting to authorities.

• Employees – Must comply with this policy and report any suspicious activity without delay.

8. Non-Compliance

Failure to comply with this policy may result in:

• Disciplinary action, including possible termination of employment or contract.

• Civil or criminal prosecution under applicable laws.

Record and Entry (R&E) Outsourcing
Website: www.recordandentry.com
Email: info@recordandentry.com
Telephone: +44 208 145 3355
Address: Ability House, 121 Brooker Road, Waltham Abbey, Essex, EN9 1JH, United Kingdom
Owned and operated by: Outsource Professional Directors (OPD) Limited
Director: Sarah Santeng
Responsible for Policies and Statements: Sarah Santeng