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Anti-Money Laundering Policy & new Customer's details

Anti-Money Laundering Policy

Introduction

V12 Management Ltd (“the Company”) is a UK registered company providing secretarial, accounting and administrative services. The business of the Company is medium risk in relation to money laundering, and in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering, we wish to put in place a clear anti-money laundering policy.

Scope of the Policy

The broad definition of money laundering means that potentially anyone could commit a money laundering offence, this includes all employees of the Company, all temporary staff and contractors.

Our policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the medium risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.

What is Money Laundering?

The principal primary legislation is The Proceeds of Crime Act 2002 (POCA), which consolidated, updated and reformed criminal law with regard to money laundering, supplemented by the Terrorism Act 2000 and the Fraud Act 2006. The principal secondary legislation is 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.

Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the UK (Section 327 POCA); entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (Section 328 POCA); and acquiring, using or possessing criminal property (Section 329 POCA).

There are also several secondary offences, failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

Customer Identification and Due Diligence

Due diligence is performed on all customers who must provide basic information.

Enhanced Due Diligence

It may be necessary for the Company to carry out enhanced due diligence on certain customers where the customer or a transaction involving the customer appears to be “high risk”. This means that there is a higher level of identification and verification of the customer’s identity required. The following non-exhaustive list of situations may indicate a “high risk”:

a new customer;
a customer not well known to the Company;
customers in known high risk industries and/or jurisdictions;
transactions that are unusual or appear to be unusual for that customer;
highly complex transaction or payment arrangements;
the transaction involves a politically exposed person (“PEP”) or an immediate family member or a close associate of a PEP;
no face to face meetings take place with the customer where this is usually expected; and

If enhanced due diligence is carried out, the Company must:

obtain additional information on the customer and on the customer’s beneficial owner(s);
obtain additional information on the intended nature of the business relationship;
obtain information on the source of funds and source of wealth of the customer and customer’s beneficial owner(s); and
conduct enhanced monitoring of the business relationship.

This may include but is not limited to the following:

checking the organisation website to confirm the identity of personnel, its business address and any other details;
attending the customer at their business address;
obtaining additional information or evidence to establish the identity of the customer and its beneficial owner(s), including checking publicly available beneficial ownership registers of legal entities such as the registers available at Companies House;
in the case of a PEP, seek the approval of senior management and establish the source of wealth and source of funds;
ensure that the first payment is made into a bank account in the customer’s name;

Data Protection

Customer details must be collected in accordance with the Data Protection Act 2018. This data can be “processed” as defined under the Data Protection Act 2018 to prevent money laundering and terrorist financing.

Record Keeping

Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 7 years from the end of any business relationship with that customer.

New customer details

In application of our Anti-Money Laundering Policy, I requested you provide personal details and IDs.

We are copying here below your answers to our form for personal identification, in order for you to confirm them and sign for approval.

Your personal contact details
- full name:
- email:
- mobile phone:
- domicile address:
IDs upload and confirmation of acceptance of conditions
- confirmation of upload to our server of copy of personal ID, personal proof of address and personal picture (selfie): confirmed
- confirmation of acceptance of our Terms of Service and Privacy Policy (in https://v12management.co.uk/): confirmed
- confirmation of acceptance of conditions, characteristics and information reported in every purchased service page (https://v12management.co.uk/): confirmed
Details of the Company
- denomination:
- incorporated by us or other supplier:
- your first role in the Company:
- your second role in the Company:
- your third role in the Company:
If you are not an Ultimate Beneficiary of the Company, indicate here their details at the best of your knowledge:
- full name:
- email:
- mobile phone:
- domicile address:
Indicate here below the name of the "representative member" (in charge of communicating with us of V12 Management) of the Company, even if it is you:
- full name of representative member: