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Anti money laundering regulations

Our mandatory legal obligations

All providers of accounting services must comply with the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Money Laundering Regulations 2017 (the “Anti Money Laundering Legislation”), which are intended to stop the activities of terrorists and other criminals by preventing them using accountancy services. If we do not comply with this legislation, we risk imprisonment.

 

In order for us to comply with legislation we must, before we can act for your company, confirm:

  • the identity of the directors,

  • at any time we may also need to obtain evidence confirming the identities of third parties, and

  • the source of any money or funding of property or other assets.

We assume that our clients are honest and law abiding. However, if at any time we have grounds to suspect that crime is being committed, we are obliged to make a report to the National Crime Agency (NCA). We are prohibited by the legislation from telling you that we have done this. In such circumstances, we cannot do any work for your company without consent from NCA.

‘Criminal property’ is money, property, other assets, rights or any benefit derived from criminal activity. Activity is considered ‘criminal’ if it is a crime under UK law, no matter how trivial. It does not matter who carried out the criminal activity. Even if you are honest in your dealings, if your property represents a benefit from someone else’s crime, we must still make a report.

If there are grounds to suspect that any monies held in a client account are derived directly or indirectly from any criminal activity whatsoever, we may not release such monies until we receive permission to do so from NCA.

Disclaimer: We will not be held liable for any loss suffered by you or any third party as a result of our compliance with the Anti Money Laundering Legislation.

We are required to have an anti-money laundering policy in place, and make you aware of it.  Our policy is set out below, and it is part of the terms under which we conduct our business.  You must agree to our policy and agree to undergo an identity verification check.  If you do not agree with our policy, or refuse to have your identity verified, we will not be able to provide you with any services.

Our commitment

Unsquared Accounting Limited's commitment to understanding and minimizing our risks in relation to money laundering and terrorist financing and our strengthening of our goals of achieving good ethical business and trading standards are contained within this policy statement. ·

We seek to achieve these goals through:

  • having robust policies and procedures in place,

  • promote a compliance culture within the company for the prevention of money laundering and terrorist financing; and

  • protection of the reputation and integrity of the company and staff.

Nominated persons

The company has appointed its principal director, Mr. Dean Pitout, as our nominated money laundering reporting officer (MLRO).  If our nominated MLRO is unable to fulfill the duties of MLRO, the following has been appointed as assistant MLRO:  Vinciworks Limited.

The MLRO is available to discuss any matters regarding the policies and procedures relating to the Money Laundering Regulations and to help you understand your obligations.

Identification of risk-sensitive areas

We have determined that the following practice areas are risk-sensitive and have put appropriate policies and procedures in place to minimize our risk in relation to the AML regulations,  (a) client due diligence, (b) reporting, (c) record-keeping, (d) internal controls, (e) risk assessment and management, (f) compliance management, and (g) communication strategy.

Awareness and training

We have implemented internal training requirements so all individuals within the company understand their responsibilities, (a) within the company's policy framework and procedures and, (b) their wider responsibilities under the anti-money laundering strategy in the United Kingdom.

We will ensure all individuals within the company are trained at regular intervals in, (a) awareness of the relevant legislation , (b) on-going understanding of their roles and responsibilities under the anti-money laundering regime, (c) updates on particular threats and alerts for the company or the profession, (d) how to recognize potential suspicious activity, (e) how to report suspicious activity, (f) the extent of the company's  exposure to risk, and (g) the company's client due diligence polices and procedures.

Record retention

We retain records for a period of six years after ceasing to act for a client in relation to, (a) clients risk assessments, (b) client identity and verification, (c) ongoing monitoring, (d) staff training, (e) internal reporting, and (f) external reporting.

This policy must not be taken as including financial records.  Financial records must be retained for a period of six years from the date of the end of the last financial period of a company.  

Reporting of suspicious activity

We have, through the MLRO, implemented procedures for assessing internal suspicion reporting and on subsequent decision making processes.

We have implemented procedures for making external suspicion reports to the Serious Organised Crime Agency (SOCA) and for the secure retention and storage of internal and external data.

Aiding law enforcement

We have, through the MLRO, implemented procedures for aiding any law enforcement agency who obtain money laundering investigation orders against our clients. These procedures relate to the collation and secure retention of the data, and to ensuring that confidentiality of the client is maintained.

Individual commitment

Our people understand the importance of the compliance culture and their roles and responsibilities in it. They are aware that penalties imposed including fines and imprisonment applies to individuals as well as to the company. Every staff member are committed to, (a) ensure that they understand the company's policies and procedures regarding AML regulations, (b) not act upon any doubt over the legitimacy of a transaction or event, (c) to follow procedures to make an internal suspicious activity report, and (d) to not speculate as to whether a crime has been committed.

Variation of this policy

The company is subject to monitoring of it's policies and procedures by an accredited agency.  In our case, that agency is HMRC.  We must, on their instruction, change this policy or any aspect of our AML regulation obligations.