Know the client
We establish the instructing person's or organisation's identity, business details and authority to instruct.
Governance and financial-crime controls
Anti-Money Laundering Policy
How UK Bailiffs identifies financial-crime risk, checks instructions and payment routes, escalates suspicious activity and applies UK sanctions controls.
Our commitment
Preventing misuse of our services and payment processes
UK Bailiff Services Ltd is committed to conducting business lawfully and to preventing its enforcement, recovery and property-support services from being used to handle criminal property, finance terrorism, evade sanctions or conceal the purpose or beneficiary of a transaction.
We apply proportionate, risk-based controls to clients, instructions, counterparties and payments. Suspicion does not require proof: an unusual circumstance is checked, documented and escalated before a decision is made.
Control framework
How we manage financial-crime risk
The level of checking reflects the instruction, the parties involved, the value and payment route, and any warning signs identified.
Understand the instruction
We consider the lawful basis, commercial purpose, supporting documents and expected activity.
Check ownership where needed
Beneficial ownership and control are examined where material, unclear, unusually complex or higher risk.
Control payments
Funds are matched to a genuine instruction, recorded, reconciled and monitored for unusual routing.
Apply enhanced checks
Higher-risk cases may require more evidence, source-of-funds enquiries, screening or senior approval.
Escalate concerns
Potential money laundering, terrorist financing or sanctions concerns go to the appointed reporting lead.
Instruction and money flow
Client, payment and refund controls
Before and during an instruction
- Confirm the client's legal identity and authority.
- Understand the service requested and apparent lawful basis.
- Review relevant leases, orders, warrants, contracts or land interests where appropriate.
- Clarify ownership, intermediaries and purpose where risk warrants it.
- Pause, decline or terminate work where required checks cannot be completed.
Receiving and returning funds
- Accept funds only where connected to a genuine instruction or lawful transaction.
- Record and reconcile receipts to the correct case, payer and client.
- Escalate unexplained third-party payments, substantial cash and overpayments.
- Normally return a refund to the original payer through the original route.
- Require verification, a recorded reason and approval for any exception.
Remain alert
Examples of warning signs
A warning sign is not proof of wrongdoing. It is a reason to stop, check, document and escalate.
Unclear identity or authority
Details cannot be verified, documents conflict or the person giving instructions cannot establish authority.
No credible purpose
The instruction or requested movement of money has no clear lawful or commercial rationale.
Unexpected third-party payment
Money comes from someone unrelated to the case, or the payer cannot explain their involvement.
Overpayment and redirected refund
A person overpays and asks for repayment to another person, account or payment method.
Unusual secrecy or urgency
Routine questions are resisted or pressure is applied to bypass normal checks and approvals.
Sanctions or serious-crime connection
A party, owner, payer or recipient may be linked to sanctions, fraud, corruption or other serious crime.
Suspicious activity
Internal reporting and escalation
Concerns are handled promptly, confidentially and without requiring the reporting person to prove criminal conduct.
Step 1
Stop and record
Preserve the relevant facts, documents, parties, dates and payment information.
Step 2
Report internally
Send the concern promptly to the Director or appointed AML reporting lead.
Step 3
Assess and control
The instruction or transaction may be paused while the concern is assessed.
Step 4
Report where required
A SAR, defence request, OFSI report or other notification is considered where legally required.
Confidentiality: nobody should alert the subject of a report or act in a way likely to prejudice an investigation. SAR material is held separately with tightly restricted access.
Governance
Training, records and review
Relevant personnel receive proportionate information or training covering warning signs, payment controls, internal reporting, confidentiality and tipping off. Records of checks, risk decisions, approvals, transactions and training are retained in accordance with the applicable statutory period and the company's retention schedule.
The Board or an authorised Director reviews this framework at least annually and after material legal, operational or risk changes.
Complete controlled document
Download the full AML policy
The PDF contains the full scope, responsibilities, risk assessment, client and payment controls, reporting process, record-keeping provisions and legal references.
UK Bailiff Services Ltd, trading as UK Bailiffs. This page describes our control framework and does not represent that every service falls within the regulated sector under the 2017 Regulations. It is not legal advice.
