Introduction

This is the policy of Amexia to comply fully with applicable provisions of the Proceeds of Crime Act 2002, Terrorism Act 2000 and the Money Laundering Regulations 2007 and all amending legislation.

Purpose

Money laundering is the practice of cleaning up money that has, for some reason, been obtained illegally. Often there is a complex trail involved so that the practice cannot be easily identified or traced.

The purpose of this policy is to ensure Amexia’s compliance with anti‐money laundering laws and regulations, to assist law enforcement in combating illegal money laundering and to minimise the risk of Amexia’s resources being used for these purposes.

Procedures

Amexia appoints money‐laundering reporting officer (MLRO) responsible for carrying out Amexia’s Anti‐Money Laundering procedures.

The MLRO will ensure that proper records are maintained on all the relevant activities and steps taken to deal with them.

Due Diligence

Amexia may carry out procedures that help it identify customers before accepting or entering into a relationship or transaction with them.

Amexia may, where applicable identify the customers and verity their identity; take adequate measures where some customers need or want their privacy intact; accept that in some cases, the identity of the customers may not be easy to verify, in which case other measures need to be developed; continuously monitor the situation; and maintain proper records of all checks made.

Policy on disclosure

If anyone knows, suspects or has reasonable grounds for thinking or suspecting that a person is engaged in money laundering or terrorist financing, they must report such matters to the MLRO immediately.

Disclosure should be made on a standard form available from the MLRO, which requires: details of the people involved; type of transaction; the relevant dates; why there is suspicion; when and how activity is undertaken amounts, etc.

The MLRO will acknowledge receipt of the disclosure within an agreed response period and consider the report and any other available information.

Once the MLRO has evaluated the disclosure or other information, they will determine if there are reasonable grounds for suspecting money laundering and the steps to be taken; or there is actual money laundering or terrorist financing; and thether they need to report the matter to the Serious Organised Crime Agency (SOCA).

All disclosure reports referred to the MLRO and reports made by them to SOCA will be retained for a minimum of five years.