AML Policy Guide
Anti-Money Laundering Policy Guide
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Walnut Tree Group Ltd (‘We’, ‘Us’, ‘Our’) take responsibility in complying with the Money Laundering Regulations 2017 (‘the Regulations’) to take active steps to combat money laundering, terrorist financing risk and tax evasion. In complying with the Regulations, this Policy outlines Our policy to check that Our clients “are who they say they are” and in line with this We have implemented internal controls and monitoring systems.
In line with The Money Laundering Regulations 2017 we are duty bound to carry out due diligence on all of our clients to confirm their identity and the source of their funds. To achieve this we may use an electronic verification system ‘Veriphy’ this system allows us to verify you from basic details using electronic data, however it is not a credit check of any kind and so will have no effect on you or your credit history. You understand that we will undertake a search with ‘Experian’ for the purposes of verifying your identity. To do so ‘Experian’ may check the details you supply against any particulars on any database (public or otherwise) to which they have access. They may also use your details in the future to assist other companies for verification purposes. A record of the search will be retained.
We may also take steps to verify the answers to any questions that We ask of a client as part of the due diligence process and for the avoidance of doubt this may involve third parties.
If We have any doubts as to a client’s identity, We reserve the right to cease to deal with them.
Dependent on the type of client, We may at Our absolute discretion either carry out a ‘Standard’ or ‘Enhanced’ level of due diligence where Our MLRO may request information over and above that set out below.
a. Identification of Clients
We carry out client due diligence and take the following steps to identify Our clients so that We can satisfy Ourselves that they are who they say they are. We therefore require each client to provide Us with the following details (where applicable) and documentary evidence reasonably requested by Us from time to time to support this:
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Full name(s);
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Full home address;
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Date of birth;
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National Insurance Number;
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Corporate identification numbers (e.g. registered company number);
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Registered or main business address; and
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Photographic identification.
Where the client is a corporate entity for example, then We may require some of the details listed above to be provided to Us in respect of the entity’s management (e.g. directors and trustees) and beneficiaries (e.g. any and all shareholders, members and persons of significant control). As a general rule of thumb a beneficiary will be the person who is behind the client and who either owns or controls the client (i.e. on whose behalf Our services are provided to).
In the event that We deal with any individual within a corporate entity that is not a director or controlling shareholder then We will require the written consent of a director or controlling shareholder in order to deal with that individual on behalf of a Client.
b. Establishing a Business Relationship
As We are entering into relationships with Our clients of a business nature, We need to obtain information on the purpose and intended nature of the relationship including where the client’s funds come from and this may include obtaining:
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Details of the client’s business or employment;
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The source and origin of funds to be used by the client;
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Copies of recent financial statements;
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Details of relationships between signatories and beneficiaries; and
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The expected level and type of activity that will take place in the relationship.
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Seller – Reason for Sale
c. Changing Circumstances
Clients should be aware that We need to keep up-to-date information about them and We may therefore require to take the steps identified in sections (a) & (b) above in the event that the client’s circumstances change (be it a change in the type of business activity or their beneficial structure). We would ask that clients inform us of any changes as soon as possible, but in any case we will as a matter of course ask about any changes that may have occurred annually.
d. Reporting
For the protection of all Our clients We operate an anti-money laundering reporting procedure. Any information that is provided during the course of providing Our services to a client will be treated in the strictest confidence and information will only ever be disclosed in line with Our Data Privacy, Cookie and Retention Policy and therefore with your consent.
One of the exceptions to this rule is under the Proceeds of Crime Act 2002 (‘the Act’) where We are required to notify the Serious and Organised Crime Agency of any matters, which come to Our knowledge, which are in contravention of this Act. It is a requirement of the Act that this information would be supplied without reference to Our client.
We reserve the right to make additional charges to Our clients as a result of any work We are obliged to undertake in compliance with the Act including any necessary application to court for guidance on how to deal with such information in compliance with the Act.
e. Cash
Please note that as a result of the Regulations and Our internal policies, which We have adopted to combat money laundering, We are not able at any stage to accept payments in cash in excess of £500.
f. Internal Processes
We have implemented internal controls and monitoring systems and have a commitment to training Our employees so that they’re aware of their responsibilities with regards to money laundering and compliance with this policy. We have an internal money laundering policy and compliance with this will be monitored by Our MLRO.
In compliance with carrying out due diligence under the Regulations, We maintain comprehensive records, including keeping either originals or copies of:
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Client identification documents;
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Daily records of transactions;
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Receipts;
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Cheques; and
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Correspondence.
These documents will be kept for a period of at least six years from the date on which a business relationship with a client ends.
For further information about how we collect, hold and protect your personal data please refer to our ‘Data Privacy Guide’, which is included in the information pack that you have been provided.
If you wish more detailed information on either our Anti-Money Laundering or Data Privacy Policies please contact the director named below who will forward copies of all policies requested to you:
Ashish Rajput (Director)