AML / CFT Policy

Our AML Policy is designed to prevent money laundering by meeting our obligations under the Anti-Money Laundering and Countering Financing of Terrorism Act 2009. This requires us to have adequate systems and controls in place to mitigate the risk of our firm being used to facilitate money laundering and terrorist financing. This AML Policy sets out the minimum standards which must be complied with and includes:

> Establishing and maintaining a Risk Assessment that assesses the potential risks our firm could face with regard to money laundering and terrorist financing;

> Establishing and maintaining a AML/CFT Programme that details our procedures, policies and controls we use to meet our obligations and assist us to combat money laundering and terrorist financing;

> Establishing and maintaining a customer due diligence, identification, verification and know your customer (KYC) procedures, including enhanced due diligence for those customers presenting higher risk, such as Politically Exposed Persons (PEPs);

> Establishing and maintaining systems and procedures to monitor on-going customer activity;

> Procedures for reporting suspicious activity internally and to the relevant law enforcement authorities as appropriate;

> The maintenance of appropriate records for the minimum prescribed periods;

> Training and awareness for all relevant employees

SANCTIONS POLICY:

We are prohibited from transacting with individuals, companies and countries that are sanctioned. We therefore screen you against recognised sanction lists e.g. the United Nations Sanctioned List.

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