Anti Money Laundering Policy

Act Finance Limited take a zero tolerance approach to being involved in illegal/illicit activity, and will fully comply with all relevant sections of the Money Laundering Regulations 2017 (ML Regs) (as amended by the MLR 2019), the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000 (TACT).

All partners and employees of the firm are under an obligation and duty to comply with the above. This policy & any related procedures aims to help partners and staff fulfil these responsibilities, by providing a clear framework, along with setting out the firm’s key principles and obligations.

Failure to fulfil these responsibilities may result in disciplinary action and may also result in criminal sanctions for the staff involved.
Breaches may also be reportable to our AML Supervisor (CILEx Regulation) which may result in professional disciplinary action.
Furthermore, a report may also have to be made to the NCA or other law enforcement agencies, which may result in a criminal investigation.

AML Legislative framework section:

Responsibilities under relevant legislation include:
ML REGS 2017 / 2019:

Risk Based Assessment
Customer Due Diligence, including ID&V requirements, assessing Source of Wealth, and application of KYC information
Enhanced Due Diligence & Ongoing Monitoring(incl. definition and treatment of PEPs
MLRO Responsibilities, SAR Reporting, Tipping Off, Police Orders
Quality Assurance
AML Record Keeping
AML Training
Compliance with International Sanctions Requirements

POCA 2002/TACT 2000: MLRO responsibilities, Suspicious Activity Reporting, Tipping Off & Police Orders

Key responsibilities of staff therefore include (but are not limited to):

Conducting an adequate risk assessment and appropriate due diligence (CDD) on clients and transactions, including PEP and sanctions checking.
 Monitoring all clients/transactions on an ongoing basis for potential money laundering or terrorist financing activity;
 Reporting any suspicious activity in respect of client or transactions to the MLRO in accordance with the firms SAR (suspicious activity reporting )procedure;
 Avoiding discussing any potential or actual SARs with clients or any third parties (“Tipping off”)
 Referring any Police/Law Enforcement queries or requests to the MLRO ;
 Undertaking any AML-related training provided by the Firm.
 Keeping appropriate records of all AML related activity

Anti Money Laundering Policy

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