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Anti 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.

We will:

  • Take reasonable steps to establish the identity of any person for whom it is proposed to provide any services where applicable.

  • 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 suspicious transactions

  • Ensure our Policy is developed and maintained in line with evolving statutory and regulatory obligations from enforcement agencies

  • 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 activities.


Risk Assessment

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 outlined above.

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, Simply-4-Business 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.


Key Issues

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.


1. Introduction

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 the Ltdonline 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.

 

 


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