1. Introduction

1.1 Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to outline the procedures and controls in place at Digitus Accountancy Ltd to prevent, detect, and report money laundering activities. This policy ensures compliance with the relevant UK legislation, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000.

1.2 Scope

This policy applies to all employees, partners, contractors, and any other individuals working on behalf of Digitus Accountancy Ltd. It covers all services provided by the firm, including but not limited to auditing, taxation, advisory, and bookkeeping services.

1.3 Definitions

  • Money Laundering: The process of making illegally-gained proceeds (i.e., “dirty money”) appear legal (i.e., “clean”).
  • Terrorist Financing: The provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used, or in the knowledge that they are to be used, in order to carry out terrorist acts.
  1. Responsibilities

2.1 Money Laundering Reporting Officer (MLRO)

[Name] is appointed as the Money Laundering Reporting Officer (MLRO) and is responsible for overseeing AML compliance, including:

  • Receiving and assessing internal Suspicious Activity Reports (SARs).
  • Making decisions on whether a SAR should be reported to the National Crime Agency (NCA).
  • Keeping accurate records of all SARs and actions taken.
  • Ensuring ongoing AML training for staff.

2.2 Employees and Partners

All employees and partners are responsible for:

  • Understanding and complying with the AML policy.
  • Reporting any suspicious activities to the MLRO without delay.
  • Attending regular AML training sessions.
  1. Risk Assessment

3.1 Risk-Based Approach

Digitus Accountancy Ltd employs a risk-based approach to AML compliance, which involves:

  • Identifying and assessing the money laundering and terrorist financing risks associated with clients, services, transactions, and geographic regions.
  • Applying appropriate measures to mitigate identified risks.

3.2 Client Risk Assessment

Clients are categorized into risk levels (low, medium, high) based on factors such as:

  • Nature and scope of the client’s business.
  • Geographic location of the client.
  • Purpose of the client relationship.
  • Client’s ownership structure.
  1. Customer Due Diligence (CDD)

4.1 Standard CDD

Standard CDD measures include:

  • Identifying the client and verifying their identity using reliable, independent source documents, data, or information.
  • Identifying the beneficial owner and taking reasonable measures to verify their identity.
  • Obtaining information on the purpose and intended nature of the business relationship.

4.2 Enhanced Due Diligence (EDD)

EDD is required for higher-risk clients and situations, such as:

  • Clients from high-risk jurisdictions.
  • Politically Exposed Persons (PEPs).
  • Unusual or large transactions with no apparent economic or lawful purpose.

EDD measures include:

  • Obtaining additional information on the client and their business.
  • Conducting enhanced ongoing monitoring of the business relationship.

4.3 Simplified Due Diligence (SDD)

SDD may be applied in low-risk situations, such as:

  • Clients who are public authorities or companies listed on a regulated market.
  • SDD measures include reduced verification requirements.
  1. Reporting Suspicious Activities

5.1 Internal Reporting

All employees must report suspicious activities to the MLRO using the internal SAR form. Suspicious activities include:

  • Unusual transactions that do not fit the client’s known business profile.
  • Transactions involving high-risk countries or clients.
  • Complex or unusually large transactions.

5.2 External Reporting

The MLRO will assess internal SARs and, if necessary, report to the NCA using the online SARs system. The MLRO must also ensure that:

  • Reports are made promptly.
  • Detailed records of all reports and decisions are maintained.
  1. Record Keeping

6.1 Record Retention

Digitus Accountancy Ltd will retain all relevant AML records for a minimum of five years, including:

  • Copies of or references to the evidence of the client’s identity obtained during the CDD process.
  • Records of all transactions and business correspondence.
  • Internal and external SARs and associated documentation.
  1. Training

7.1 Training Program

Digitus Accountancy Ltd provides ongoing AML training to all relevant staff, which includes:

  • Understanding money laundering and terrorist financing risks.
  • Familiarity with AML legislation and regulations.
  • Recognizing and reporting suspicious activities.
  • Updates on new AML threats and regulatory changes.
  1. Monitoring and Review

8.1 Compliance Monitoring

The MLRO will conduct regular reviews and audits of the AML program to ensure its effectiveness and compliance with regulatory requirements. This includes:

  • Regularly reviewing and updating the AML policy.
  • Monitoring adherence to CDD, EDD, and SDD procedures.
  • Evaluating the effectiveness of staff training programs.

8.2 Policy Review

This AML policy will be reviewed and updated at least annually or more frequently if required by changes in legislation, regulations, or business operations.

  1. Non-Compliance and Disciplinary Action

Failure to comply with this AML policy may result in disciplinary action, including termination of employment or partnership. Non-compliance may also result in legal and regulatory penalties.