Business Expert is committed to maintaining the highest standards of ethical conduct and legal compliance to prevent, detect and report financial crime and money laundering activities.
We have developed this Anti-Financial Crime & Anti-Money Laundering (AFC & AML) Policy in accordance with UK law, including the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and The Money Laundering and Terrorist Financing (Amendment) (No.2) Regulations September 2022.
2. Scope
This policy applies to all our employees, contractors, and third parties associated with Business Expert, including but not limited to partners, suppliers, and affiliates.
3. Objectives
The objectives of this policy are to:
a. Prevent and detect financial crime, money laundering, and terrorist financing activities within Business Expert’s operations. b. Ensure compliance with applicable UK laws and regulations. c. Implement and maintain effective risk-based measures to mitigate the risk of financial crime and money laundering. d. Foster a culture of ethical behaviour and compliance within the organization.
4. Compliance Officer
Business Expert has a designated Compliance Officer who is responsible for:
a. Overseeing the implementation and effectiveness of this policy.
b. Monitoring and reporting any suspicious activities to the appropriate authorities.
c. Ensuring that all employees receive adequate training and support to understand and adhere to this policy.
5. Risk Assessment
Business Expert conducts ad-hoc risk assessments to identify, assess, and mitigate the potential risks of financial crime and money laundering within its operations. The risk assessments include:
a. Assessing the risks associated with our products, services, and customers.
b. Implementing effective controls to mitigate identified risks.
c. Regularly reviewing and updating the risk assessment to reflect changes in our operations, the regulatory environment, and the threat landscape.
6. Customer Due Diligence (CDD)
Business Expert has appropriate CDD measures to verify the identity of our customers and assess their risk profile.
These measures include:
a. Verifying the identity of customers where required using reliable, independent source documents, data, or information.
b. Understanding the purpose and nature of the business relationship.
c. Conducting ongoing monitoring of the business relationship where required and the customer’s transactions to ensure consistency with the customer’s risk profile.
Enhanced Due Diligence (EDD) will be applied to potential high-risk customers or situations, including but not limited to Politically Exposed Persons (PEPs), customers from high-risk jurisdictions, and complex or unusually large transactions
7. Record Keeping
In line with GDP requirements and where applicable Business Expert maintains accurate and up-to-date records of all customer identification and transaction data for a minimum period of five years from the end of the business relationship or the completion of the transaction, whichever occurs later. These records will be made available to relevant authorities upon request before being destroyed.
8. Reporting of Suspicious Activities
All employees of Business Expert have a responsibility to report any suspicions of financial crime or money laundering activities to the Compliance Officer. The Compliance Officer will assess the information and, if appropriate, submit a Suspicious Activity Report (SAR) to the UK Financial Intelligence Unit (UKFIU).
9. Training and Awareness
Business Expert provides regular training to all employees to ensure they understand their roles and responsibilities in preventing and detecting financial crime and money laundering. This includes training on this policy, customer due diligence, record keeping, and reporting suspicious activitie
10. Review and Update – This policy is reviewed at least annually or more frequently as needed to ensure its continued effectiveness and compliance with current UK laws and regulations. Any changes to the policy is communicated to all employees and relevant stakeholders.
11. Policy Breaches and Sanctions
Any employee who breaches this policy or fails to report suspected financial crime or money laundering activities may face disciplinary action, up to and including termination of employment. In addition, Business Expert may report any such breaches to relevant authorities, which may result in civil or criminal penalties for the individual and/or the organization.
12. Whistleblowing
Business Expert encourages a culture of openness and transparency. Employees are encouraged to report any concerns or suspicions of financial crime or money laundering activities without fear of retaliation. Confidentiality will be maintained for whistle-blowers, and appropriate measures will be taken to protect them from any potential retaliation or victimisation.
13. Third-Party Relationships
Business Expert ensures that all third parties, including partners, suppliers, and affiliates, comply with this policy and applicable anti-financial crime and anti-money laundering laws and regulations. We conduct appropriate due diligence on third parties before entering into any business relationship and where appropriate monitor their compliance on an ongoing basis.
14. Cooperation with Authorities
Business Expert is committed to cooperating with relevant authorities, including the UK Financial Intelligence Unit (UKFIU), the Financial Conduct Authority (FCA), and other regulatory and law enforcement agencies, in their efforts to combat financial crime and money laundering.