AML, CTF & CPF Policy Summary

We have a zero-tolerance approach to money laundering, terrorist financing (CTF), proliferation financing (CPF), tax evasion, fraud, bribery and sanctions breaches. Our partners and staff are required to act with integrity and to actively prevent the firm from being used to facilitate financial crime.

We maintain a documented firm-wide risk assessment covering client, geographic, service, delivery channel, transaction and PF-specific risks. This assessment is reviewed at least annually and after material changes in law, guidance, our client base or services. Each engagement is risk-rated before acceptance and re-assessed periodically thereafter.

• Verification of the identity of clients, beneficial owners and persons with significant control.
• Understanding ownership and control structures, the purpose and intended nature of the engagement.
• Assessing source of funds and, where relevant, source of wealth.
• Use of reputable digital identity verification (IDV) tools, including biometric and document checks, to support reliable, auditable onboarding.

We apply EDD where a client, beneficial owner, jurisdiction or transaction presents higher risk — including politically exposed persons (PEPs), their family members and known close associates, complex or opaque structures, high-risk third countries, and any case where we identify red flags. EDD measures may include additional identity and source-of-funds evidence, senior approval to onboard or continue, and intensified ongoing monitoring.

All clients, beneficial owners and relevant connected parties are screened against UK (OFSI), UN, EU and other relevant sanctions lists, PEP databases and adverse media at onboarding and on an ongoing basis. Positive or potential matches are escalated to the MLRO before any work proceeds and reported to OFSI where required.

In line with the updated MLRs, our risk assessment and controls explicitly address proliferation financing — the raising, moving or making available of funds or assets that could contribute to weapons of mass destruction programmes or related sanctions evasion. CPF risk indicators are integrated into client onboarding, screening and ongoing monitoring.

We monitor the business relationship on a risk-sensitive basis throughout the engagement, including scrutiny of transactions and activity for consistency with what we know about the client, periodic refresh of CDD information and re-screening against sanctions and PEP lists.

The firm has a nominated Money Laundering Reporting Officer (MLRO) and a deputy. All partners and staff must report knowledge or suspicion of money laundering, terrorist financing or proliferation financing internally to the MLRO without delay. Where appropriate, the MLRO submits a Suspicious Activity Report (SAR), and a Defence Against Money Laundering (DAML) request where required, to the National Crime Agency (NCA).

We will not disclose to a client or any third party that an internal report or external SAR has been or may be made, in line with sections 333A and 342 of the Proceeds of Crime Act 2002 and equivalent provisions of the Terrorism Act 2000.

CDD records, transaction information and supporting evidence are retained securely for the periods required by law (generally five years from the end of the business relationship or transaction). Records are held in access-controlled, encrypted systems and handled in accordance with UK GDPR and our Privacy Policy.

All partners and relevant staff complete AML, CTF, CPF, sanctions and fraud awareness training on induction and at least annually, with additional updates whenever law, guidance or our risk assessment changes materially. Training is recorded and effectiveness is reviewed.

Overall responsibility for AML/CTF/CPF compliance sits with the firm's senior management. Day-to-day oversight is delegated to the MLRO. We are supervised by the Association of Accounting Technicians (AAT) and follow the CCAB Anti-Money Laundering Guidance for the Accountancy Sector. Independent reviews of our AML framework are carried out on a risk-sensitive basis.