Anti- Money Laundering (AML) Policy
Purpose
The Anti-Money Laundering (AML) policy at One Direction Accounting Service Ltd aims to describe the procedures and controls in place to prevent, detect, and report money laundering activities. It ensures compliance with the UK laws, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000.
scope
This policy applies to all employees, partners, contractors, and others working for One Direction Accounting Ltd. It covers all services offered by the firm, such, accounting services.
Definition
Money Laundering: The process of making illegally obtained money (i.e., "dirty money") appear legal ("clean").
Terrorist Financing: The collection or provision of funds, by any means, with the intention or knowledge that they will be used to carry out terrorist activities
Money Laundering Reporting Officer (MLRO)
The appointed Money Laundering Reporting Officer (MLRO) is responsible for managing AML compliance, which includes
Handling and evaluating internal Suspicious Activity Reports (SARs).
Deciding if a SAR needs to be reported to the National Crime Agency (NCA).
Keeping detailed records of all SARs and actions taken.
Ensuring continuous AML training for employees.
Employees and Partners
All employees and partners must:
Understand and follow the AML policy.
Promptly report any suspicious activities to the MLRO.
Participate in regular AML training sessions.
Risk-Based Approach
One Direction Accounting Services Ltd uses a risk-based strategy for AML compliance, which involves:
Identifying and evaluating the risk of money laundering and terrorist financing related to clients, services, transactions and regions.
Implementing suitable measures to reduce identified risks.
Client Risk Assessment
Clients are classified into risk level (low, medium, high) based on factors like:
The nature and scope of the client's business.
The client's geographic location
The purpose of the client relationship.
Client's ownership structure.
Customer Due Diligence (CDD)
Standard CDD procedures involve:
Confirming the client's identity through reliable, independent documents, data, or information.
Identifying the beneficial owner and taking reasonable steps to verify their identity.
Gathering information on the purpose and expected nature of the business relationship.
Enhanced Due Diligence (EDD)
EDD is necessary for clients and situations with higher risks, such as:
Clients from high-risk regions.
Politically Exposed Persons (PEPs).
Unusual or large transactions without a clear economic or legal purpose.
EDD procedures include:
Gathering extra information about the client and their business.
Performing increased monitoring of the business relationship.
Simplified Due Diligence (SDD)
SDD can be used in low-risk scenarios, such as:
Clients who are government entities or companies listed on a regulated market.
SDD procedures involve fewer verification requirements.
Internal Reporting
All employees must report suspicious activities to the MLRO using the internal SAR form.
Suspicious activities include:
Unusual transactions that do not align with the client's known business profile.
Transactions involving high-risk countries or clients.
Complex or unusually large transactions.
External Reporting
The MLRO will review internal SARs and, if needed, report to the NCA using the online SARs system. The MLRO must also ensure:
Reports are submitted promptly.
Detailed records of all reports and decisions are kept.
Record Retention
One Direction Accounting Services Ltd will keep all relevant AML records for at least five years, including:
Copies or references to evidence of the client's identity obtained during the CDD process.
Record of all transactions and business correspondence.
Internal and external SARs and related documentation.
Training Program
One Direction Accounting Services Ltd provides ongoing AML training to all relevant staff, which covers:
Understanding money laundering and terrorist financing risks.
Recognising and reporting suspicious activities.
Updates on new AML threats and regulatory changes.
Monitoring
The MLRO will carry out regular evaluations and audits of the AML program to ensure it is effective and meets regulatory standards. This involves:
Consistently reviewing and updating the AML policy.
Checking compliance with CDD, EDD, and SDD procedures.
Assessing the effectiveness of employee training programs
Policy Review
This AML policy will be examined and refreshed at least once a year, or more often if needed due to changes in laws, regulations, or business activities.
Non-Compliance and Disciplinary Action
Not adhering to this AML policy may lead to disciplinary measures, which could include ending employment or partnership. Non-compliance may also lead to legal and regulatory consequences.