This policy document addresses the requirements of the Company (Velocity Marketplaces Ltd) with respect to the compliance of customers and staff to its Anti-Money Laundering Policy (AMLP).
Velocity Marketplaces Ltd are committed to the highest standard of money laundering and terrorist financing prevention. This includes anti-fraud, anti-corruption and anti-bribery which are covered within their own policy documents. We aim to have adequate and proportionate risk assessment tools specific to financial crime risks.
The company has a nominated Anti-Monetary Laundering Reporting Officer (MLRO), Martin Purcell FCIM FIDM, COO of the company and also has a dedicated due diligence program with measures and controls in place to ensure compliance with the current regulations, laws and standards. Velocity’s aim is to ensure a continuous practice of monitoring customers and business partners and staff training for an inclusive approach.
The company understands that it has a responsibility to identify and combat money laundering across a broad spectrum. This includes financial transactions, including possessing, or in any way dealing with, or concealing, the proceeds of any crime. Our organisation operates in a transparent environment with assessment, monitoring and reporting at the core of all business functions. We are dedicated to the prevention of financial crime and continue to improve upon existing measures.
2 What is Money Laundering?
3 Goldsmiths’ Obligations
4 Employee Obligations
5 Know Your Customer (KYC) and Customer due diligence (CDD) including Financial Sanctions Targets
6 Money Laundering Reporting Officer (MLRO)
7 Disclosure Procedure to be followed by Employees
8 Action and Disclosure by the MLRO
11 Communication and training
12 Equality and diversity
Ownership: Chief Operating Officer /Anti-Money Laundering Reporting Officer (MLRO)
Policy approved by Audit and Risk Committee Policy approved 13 June 2020 Review date May 2023.
This policy will be reviewed triennially by the Audit and Risk Committee unless there is a change in the UK legislative framework that requires it to be updated and reviewed sooner. Minor updates, for example, name changes, will be made periodically on the authority of the MLRO as required. Anti-Money Laundering (AML) Policy Velocity Marketplaces Ltd
1.1 Velocity Marketplaces Ltd (‘VML’) is committed to observing the provisions of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, Part 7 – Money Laundering Offences and the Terrorism Act 2000 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2013) in all of its affairs, whether academic or business-related. This policy aims to ensure that VML and all its employees comply with the legislation and that due diligence is applied in relation to ‘know your customer’ principles.
1.2 This policy sets out the procedure to be followed if money laundering is suspected and defines the responsibility of individual employees in the process.
1.3 VML has a zero-tolerance policy towards money laundering and is committed to the highest level of openness, integrity and accountability, both in letter and in spirit. The penalties for these offences are severe and can mean up to 14 years imprisonment and/or an unlimited fine for the employees and executives responsible. In addition, there would be significant reputational damage for VML
1.4 This policy applies to all staff of VML and its subsidiary companies and applies to all income and expenditure. Any breach of this policy will be a serious matter, may result in disciplinary action and could result in an employee becoming personally liable for criminal prosecution.
1.5 In addition to the Anti-Money Laundering Policy, the following related policies are in force: • Financial Regulations • Anti-Corruption and Bribery • Conflicts of Interest • Whistleblowing • Fraud • Gift Acceptance Policy and Code of Ethical Fundraising Practice
2.1 The introduction of the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 has broadened the definition of money laundering and has widened the range of activities controlled by the statutory framework.
2.2 Money laundering covers a wide variety of crimes, it can include anything from which individuals or companies derive a pecuniary benefit, directly or indirectly, and can include many crimes that are not initially thought of as connected with money laundering. There is a risk where there are large volumes of cash transactions and where customer identification is not always easy, for example, cash received from overseas students.
2.3 Money laundering is the process by which criminally obtained money or other assets (criminal property) are exchanged for ‘clean’ money or other assets with no obvious link to their criminal origins. Criminal property may take any form, including money or money’s worth, securities, tangible property and intangible property. It also covers money, however, come by, which is used to fund terrorism.
2.4 Money laundering offences include:
3.1 VLM has a responsibility to:
3.2 VML adopts a risk-based approach towards anti-money laundering and conducting due diligence. Whilst much of the VLM’s financial activities could be considered relatively low risk from the perspective of money laundering, all staff need to be vigilant against the financial crime and fraud risks that the company faces.
3.3 VML assesses risks relevant to our operations and puts in place the processes and procedures that we deem necessary to mitigate these risks. We determine the appropriate level of due diligence by looking at the geographic and customer risk factors based on the EU Directive and set out in MLR2017 and analysing the VLM’s potential exposure to money laundering (the source of funds) or terrorist financing (the destination of funds). Our AML risk report is attached in Appendix 1.
4.1 Money laundering legislation applies to all of VLM’s employees. Any member of staff could be committing an offence under the money laundering laws if they suspect money laundering, or if they become involved in some way and do nothing about it. If any employee suspects that money laundering activity is or has taken place or if any person becomes concerned about their involvement, it must be disclosed as soon as possible to the MLRO. Failure to do so could result in their becoming personally liable to prosecution. Guidance on how to raise any concerns is included in this policy document.
5.1 VLM must be reasonably satisfied as to the identity of an employee, customer or third party and satisfactory evidence of identity must be obtained and retained.
5.2 Our customer due diligence follows the principles of Know Your Customer (KYC). The three components of KYC are:
For employees: • Passport and/or Visa • Birth Certificate • Correspondence with staff at their home address
For customers or third parties: • Letters or documents proving name, address and relationship
For organisations not known to VLM, the following evidence can be helpful: • Letter-headed documents • Invoices that show a company’s registered office and VAT number • Checking on limited company authenticity with Companies House • A credit check
5.3 VLM has procedures for performing customer due diligence (“CDD”), and transaction monitoring arrangements on a risk-managed basis. We have documented this in the risk assessment in Appendix 1.
5.4 CDD records must be retained for five years from the date on which reliance commences as failure to do so is a criminal offence
6.1 VLM has appointed a Money Laundering Reporting Officer (the “MLRO”), who is the COO, and a Deputy MLRO, who is the CTO to act in his absence. The MLRO is the officer nominated to receive disclosures in respect of suspected transactions or activity within VLM.
7.1 Where you know or suspect that money laundering is taking or has taken place, or you become concerned that your involvement in a transaction may amount to a breach of the regulations, you must disclose this immediately to the MLRO.
7.2 Your report should include as much detail as possible including:
7.3 Once you have reported your suspicions to the MLRO you must follow any instructions given to you. You must not make any further enquiries unless instructed to do so by the MLRO. At no time and under no circumstances should you voice any suspicions to the person(s) you suspect of money laundering, nor should you discuss this matter with any colleagues.
7.4 If appropriate the MLRO will refer the case to the National Crime Agency (NCA) which will undertake any necessary investigation. This may include consent to continue with a particular transaction and care should be taken not to ‘tip off’ the individuals concerned, otherwise, you may be committing a criminal offence. The penalty for tipping off is 5 years imprisonment and/or an unlimited fine.
8.1 On receipt of a disclosure report the MLRO will:
8.2 Once the MLRO has evaluated the case, a timely determination will be made as to whether:
8.3 Where the MLRO concludes that the case should be disclosed to NCA this needs to be done:
8.4 Where the MLRO concludes that there are no reasonable grounds to suspect money laundering then consent will be given for transactions to proceed and the disclosure report will be marked accordingly.
9.1 There are Financial sanctions that relate to specific countries or terrorist groups, known as ‘regimes’. What is prohibited under each financial sanction depends on the financial sanction regulation. Regulations are imposed by the United Nation’s Security Council – the UK is a member so automatically imposes all financial sanctions created by the UN;
9.2 The UK government publishes frequently-updated guidance on financial sanctions targets, which includes a list of all targets. This guidance can be found at: www.gov.uk/government/publications/financial-sanctionsconsolidated-list-of-targets/consolidated-list-of-targets.
9.3 We will monitor the relevant websites to review Sanctioned Parties and ensure that the VLM does not transact with Sanctioned Parties.
10.1 By keeping comprehensive records VLM is able to show that we have complied with the Money Laundering Regulations. This is crucial if there is a subsequent investigation into one of our customers/staff or transactions.
10.2 The types of records kept may include:
10.3 Records may be kept in any of the following formats:
10.4 Records must be kept for five years beginning on either:
10.5 The MLRO will retain any disclosure reports and any associated relevant documents in a confidential file for a minimum of five years.
10.6 VLM is required to retain records for at least seven years after ceasing to transact with an employee, supplier or customer including records of risk assessment, identity and verification and ongoing monitoring. These records are required for other purposes, such as tax compliance, as well as anti-money laundering.
11.1 This policy ensures staff understand their responsibilities under the AML regime, the company’s due diligence procedures and how to report suspicious activity. The policy is published on the company’s intranet via policies and Procedures web pages and communicated to staff via internal communication, such as the staff newsletter.
12.1 There are no equality and diversity impacts of this policy