Money Laundering Policy
HM Revenue & Customs Anti-Money Laundering Registration No. 12709698
It is Web-Merchant Services Limited’s policy to ensure that our
company, its senior management and all of our company's employees are
committed to complying with all legislation and appropriate guidelines
designed to combat money laundering activity, the funding of terrorist
or criminal activity in the jurisdictions in which we operate.
Take reasonable steps to establish the identity
of any person for whom it is proposed to provide any services where
Retain identification and transactional documentation
as defined in the legislation in the jurisdiction in which we operate
Provide initial and on going training to ensure
all relevant staff are aware of their personal responsibilities and
the anti-money laundering procedures in respect of identifying clients,
monitoring, record-keeping, remaining vigilant at all time and reporting
Ensure our Policy is developed and maintained
in line with evolving statutory and regulatory obligations from enforcement
Report to the relevant authority where there
are reasonable grounds to suspect that a money laundering offence
has been committed
We will at all times ensure the protection
of our staff, and safeguard our organisation and reputation against
the threat of money laundering and the funding of terrorist and criminal
Web-Merchant Services Ltd is a supplier of Company Formation services.
In all cases the formation software is working with the Companies House
electronic filing system for the formation of new companies that come
under the jurisdiction of Companies House.
Our trading will be based on the following principles and markets: -
1) No financial transactions or money handling will be undertaken by
Web-Merchant Services Ltd, other than the charges made for the services
2) Web-Merchant Services Ltd does not offer any Banking, Accounting
or Secretarial services.
3) The client base will be mainly professional accountants, solicitors
and perhaps other formation agents. In rare cases we may form a company
for a client who have contacted us.
Risks, vulnerability and due diligence
1) Any companies formed by Web-Merchant Services Ltd will not have
the ability to transfer or process financial transactions as a result
of the company being formed. In order to transfer or process financial
transactions, the company will have to open a bank account or other
similar arrangement, which will be subject to the anti-money laundering
regulations for that particular institution. For example, in order to
open a bank account, it is now the normal procedure for the bank to
ask for proof of Identity, i.e. passport, utility bill or similar.
2) The above will particularly apply to companies formed for individuals.
In terms of the due diligence required by the anti-money laundering act,
Web-Merchant Services Ltd will take the following steps to identify the
individuals who require the company to be formed, or the individuals within
an accounting, solicitors or formation agent’s practice, who are
instructing Web-Merchant Services Ltd: -
1) In the case of individuals wishing to form a company, Web-Merchant
Services Ltd will not be required to follow the due diligence procedures
established by the Money Laundering Directive as there will not be a
longer term ongoing business relationship that has been established.
Our professional clients will be subject to their own organisations
and professional body’s procedures in order to make sure that
they are complying with the Money Laundering Directive.
2) Web-Merchant Services Ltd will hold any relevant data as described
above on record, as required by the anti-money laundering act 2007 and
will fully comply with the Data Protection Act 1998.
Web-Merchant Services Ltd will do all it can to prevent the company and
its staff being exposed to money laundering, identify the potential areas
where it may occur, and to comply with all legal and regulatory requirements,
especially with regard to the reporting of actual or suspected cases.
Web-Merchant Services Ltd is committed to the prevention, detection and
reporting of money laundering. All employees must be vigilant for the
signs of money laundering. Any employee who suspects money laundering
activity must report this promptly to the Money Laundering Reporting Officer,
or Deputy Money Laundering Officer.
The Proceeds of Crime Act 2002 (POCA) consolidated, updated and reformed
criminal law with regard to money laundering Web-Merchant Services Ltd
will take reasonable steps to minimise the likelihood of money laundering
occurring by putting in place proper policies and procedures.
This policy has therefore been adopted in order to introduce safeguards
to help identify and report on instances where money laundering is suspected.
2. Scope of the Policy
This Policy applies to all employees of Web-Merchant Services Ltd and
aims to maintain the high standards of conduct, by preventing criminal
activity through money laundering. The policy sets out the procedures,
which must be followed (for example the reporting of suspicions of money
laundering activity) to enable Web-Merchant Services Ltd to comply with
its legal obligations.
3. What is Money Laundering?
Money laundering can be defined as the process to move illegally acquired
cash through financial systems so that it appears to be from a legitimate
source. Money laundering offences include: concealing, disguising, converting,
transferring criminal property or removing it from the UK (Section 327
of the Act); entering into or becoming concerned in an arrangement which
you know or suspect facilitates the acquisition, retention, use or control
of criminal property by or on behalf of another person (Section 328
of the Act); and acquiring, using or possessing criminal property (Section
329 of the Act).
There are also two secondary offences, failure to disclose any of the
three primary offences above; and ‘tipping off’ whereby
somebody informs a person or persons who are, or who are suspected of
being involved in money laundering, in such a way as to reduce the likelihood
of their being investigated or prejudicing an investigation.
Any member of staff could potentially be caught by the money laundering
provisions, if they suspect money laundering and either become involved
with it in some way, and/or do nothing about it. This Policy sets out
how any concerns should be raised.
While the risk to Web-Merchant Services Ltd of contravening the legislation
is low, it is important that all employees are familiar with their responsibilities
as serious criminal sanctions may be imposed for breaches of the legislation.
The key requirement of employees is to promptly report any suspected
money laundering activity to the Money Laundering Reporting Officer.