AML & CTF Policy Summary

We take the prevention of money laundering, terrorist financing and other economic crime seriously. We follow the CCAB Anti-Money Laundering Guidance for the Accountancy Sector and applicable UK law including the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Sanctions and Anti-Money Laundering Act 2018.

We maintain a documented firm-wide risk assessment and assess every client and engagement for risk before accepting work. Higher-risk relationships receive enhanced due diligence and ongoing monitoring.

• Identity verification of clients, beneficial owners and persons with significant control.
• Understanding the purpose and nature of the engagement and source of funds where relevant.
• Sanctions and PEP screening before onboarding and on a periodic basis.
• Re-verification when circumstances change or where higher risk is identified.

The firm has a nominated Money Laundering Reporting Officer (MLRO). All internal suspicions are reported to the MLRO, who decides on disclosure to the National Crime Agency. Records are retained for the period required by law.

All partners and staff complete AML training on induction and at least annually thereafter, with additional updates whenever law or guidance changes materially.

We will never disclose to a client or third party that an internal or external suspicious activity report has been made, in line with sections 333A and 342 of POCA.