Anti-Money Laundering (AML) Policy

AVPros Anti-Money Laundering (AML) Policy

 1.⁠ ⁠Legal Framework

 3.⁠ ⁠Ongoing Monitoring

In line with the Money Laundering Regulations 2017, we will continue to monitor customers on an ongoing basis to ensure their activities are consistent with their business and risk profile.

Our monitoring process includes:

• Regular review of customer transactions and activities for suspicious behavior.

• Updating CDD information as necessary, especially for customers considered high-risk.

• Using appropriate software or systems to track transactions and detect potential suspicious activity.

 4.⁠ ⁠Reporting Suspicious Activity

We will immediately report any suspicious activity to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR). This includes activity that we believe may involve money laundering or the financing of terrorism.

• Suspicious Activity Reports (SARs) will be reviewed by our designated Anti-Money Laundering Officer (AML Officer) who will decide whether a report should be submitted.

• All reports will be kept confidential to avoid tipping off any individuals involved in suspicious activity.

 5.⁠ ⁠AML Officer

AVPros has designated an Anti-Money Laundering Officer (AML Officer) who is responsible for overseeing the implementation of this policy and ensuring compliance with all AML laws. The AML Officer will:

• Monitor all transactions for suspicious activity.

• Ensure that staff are trained and aware of AML laws and responsibilities.

• Ensure that all records are maintained and stored securely for a minimum of five years, as required by UK laws

 6.⁠ ⁠Employee Training and Awareness

All employees involved in customer interactions or financial transactions will undergo training to recognise signs of money laundering or terrorist financing. This training will be updated annually to reflect any changes in AML laws and regulations.

Training will cover:

• How to identify suspicious transactions.

• How to report suspicious activity.

• The legal obligations of the company and employees in relation to AML.

 7.⁠ ⁠Record Keeping

We will maintain comprehensive records of all transactions, CDD checks, and SARs for a minimum of five years, as required by UK law. These records will be available for inspection by regulatory authorities if needed.

 8.⁠ ⁠Internal Controls and Auditing

To ensure compliance with this policy, we will implement robust internal controls and auditing mechanisms. These will include:

• Regular audits of the CDD process and transaction monitoring systems.

• Periodic reviews of our compliance with the latest AML regulations.

 9.⁠ ⁠Beneficial Ownership

We will ensure that we identify and verify the beneficial ownership of corporate clients as required by the Fifth Anti-Money Laundering Directive (5AMLD). This includes obtaining information about individuals who own or control a company, directly or indirectly.

10.⁠ ⁠High-Risk Customers

For customers deemed to be high-risk, we will apply Enhanced Due Diligence (EDD) measures. High-risk customers may include:

• Customers from high-risk jurisdictions or countries with poor AML controls.

• Politically Exposed Persons (PEPs) and their close family members or associates.

• Customers engaging in complex or unusually large transactions that do not align with their known business profile.

EDD measures include:

• Obtaining additional information about the customer’s source of funds.

• Scrutinising transactions more closely.

11.⁠ ⁠AML Policy Review

We will review and update our AML policy regularly to ensure that it reflects the latest legal requirements and best practices in the industry. Any changes to AML legislation, both domestic and international, will be incorporated into the policy.

Contact Information:

If you have any questions or concerns about our Anti-Money Laundering policy, or if you need to report suspicious activity, please contact:

• AML Officer: Kieran Connolly

• Email: admin@avpros.co.uk

• Phone: 020 355 5067

By implementing this policy, AVPros aims to protect its business from being used for money laundering or terrorism financing, as required by the UK’s AML laws. All employees are required to adhere to this policy to ensure that AVPros remains compliant with all relevant legal and regulatory requirements.

This updated policy includes all necessary provisions to ensure compliance with UK AML laws, including customer due diligence, ongoing monitoring, reporting of suspicious activity, and maintaining records. It also specifies enhanced due diligence for high-risk customers and the designation of an AML officer.