Anti-Money Laundering Policy

Introduction

This policy covers the Anti-Money Laundering (AML) guidance and procedures for Hazlemere Window Company Ltd

Policy Aims

To do all we can to prevent the company and its staff being exposed to Money Laundering and financial crime, to identify the potential areas where it may occur, and to comply with all legal and regulatory requirements.

Definition of Money Laundering

Money Laundering is the process by which criminals attempt to conceal the true ownership of the proceeds of their criminal activities to make it appear they have come from legitimate sources.

The Money Laundering Reporting Officer (MLRO)

The designated MLRO is Mrs Rachel Braham-Hill and can be contacted on 01494 536000 or 01494 897600 and by email r.braham-hill@hazlemere.co.uk

 Responsibilities of the MLRO

  • To act as an control point for procedures, legislation, inspection, reporting, training
  • To provide guidance and training to staff on Money Laundering issues
  • To retain accurate and thorough records.

Awareness Raising and Staff Training

An overview of anti-money laundering responsibilities is provided to all employees handling financial applications in relation to our credit brokerage services in the first two weeks of joining the company. On an annual basis all appropriate staff are provided with refresher training to ensure they remain aware of their responsibilities.

Identifying Risk

  • Where a customer’s credit application is outside what we would usually expect or is unnecessarily complicated.
  • We must also pay regard to the size and source of an applicant’s deposit and the size of the transaction they wish to carry out.

Suspicious Transactions/Behaviour

It is every individual member of staff’s responsibility to identify suspicious transactions/behaviour and report them to the MLRO via email using the Suspicious Activity Report Form to report (see over). If any employee is unable to use email this should be handed in person to the MLRO.

Retention of Records

All files, including evidence of verification of identity and transaction information, must be retained for six years after our business relationship has ended. If an investigation is in progress then the records must be retained until the authorities confirm the case has been closed.  Records may be retained on paper of electronic medium.