Anti-Money Laundering (AML) and Suspicious Activity Policy

1. Purpose

This Anti-Money Laundering (AML) and Suspicious Activity Policy outlines UK Bailiff Services Ltd's commitment to preventing money laundering, terrorist financing, and other financial crimes. The policy ensures compliance with UK laws, including but not limited to:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000

This policy applies to all employees, contractors, and agents acting on behalf of UK Bailiff Services Ltd.

2. Scope

This policy applies to all business activities, including:

• Debt recovery and enforcement services
• Client onboarding and interactions
• Financial transactions related to services provided
• Any activities involving the handling of funds or assets

All staff are required to adhere to this policy and report any suspicious activities promptly.

3. Definitions

• Money Laundering: The process of making illegally obtained funds appear legitimate by passing them through legitimate transactions or investments.
• Terrorist Financing: Providing or collecting funds to support terrorist activities.
• Suspicious Activity: Any transaction, behavior, or client activity that appears unusual, inconsistent with known patterns, or potentially linked to money laundering or terrorist financing.
• MLRO: Money Laundering Reporting Officer, responsible for overseeing AML compliance and reporting suspicious activities.

4. Roles and Responsibilities

4.1 Money Laundering Reporting Officer (MLRO)

UK Bailiff Services Ltd will appoint a designated MLRO to:

• Oversee the implementation of this AML policy.
• Receive and investigate reports of suspicious activities.
• Report suspicious activities to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR) when necessary.
• Ensure staff training on AML obligations.
• Maintain records of AML activities and decisions.

4.2 Employees

All employees must:

• Be vigilant for signs of money laundering or suspicious activity.
• Report any concerns to the MLRO immediately.
• Complete mandatory AML training annually.
• Follow client due diligence and record-keeping procedures.

5. Client Due Diligence (CDD)

UK Bailiff Services Ltd will conduct Customer Due Diligence (CDD) to verify the identity of clients and understand the nature of their business. CDD is required:

• When establishing a business relationship.
• For transactions involving high-risk clients or unusual activity.
• When there is suspicion of money laundering or terrorist financing.

5.1 CDD Procedures

1. Identity Verification:
   • For individuals: Obtain and verify government-issued photo ID (e.g., passport, driving license) and proof of address (e.g., utility bill).
   • For businesses: Obtain company registration documents, VAT number, and identification of beneficial owners.
2. Source of Funds: Verify the source of funds for significant transactions (e.g., payments for large debt settlements).
3. Purpose of Transaction: Understand the purpose and intended nature of the client's business with UK Bailiff Services Ltd.
4. Enhanced Due Diligence (EDD): Apply EDD for high-risk clients, including:
   • Politically Exposed Persons (PEPs).
   • Clients from high-risk jurisdictions (as per FATF lists).
   • Clients with complex or unusual transaction patterns.

5.2 Ongoing Monitoring

• Regularly review client activities for consistency with known information.
• Update CDD records when there are material changes to client circumstances.
• Escalate any discrepancies to the MLRO.

6. Suspicious Activity Reporting

6.1 Identifying Suspicious Activity

Employees should be alert to:

• Payments from unrelated third parties.
• Large cash payments or unusual payment methods.
• Clients providing incomplete or inconsistent information.
• Transactions with no apparent economic or lawful purpose.
• Clients linked to high-risk jurisdictions or sanctioned entities.

6.2 Reporting Procedure

1. Internal Reporting: Employees must report suspicious activity to the MLRO immediately, providing all relevant details (e.g., client name, transaction details, nature of suspicion).
2. MLRO Investigation: The MLRO will review the report and determine if a Suspicious Activity Report (SAR) is required.
3. External Reporting: If necessary, the MLRO will file a SAR with the NCA via the online reporting system within 7 days of suspicion being identified.
4. Confidentiality: Employees must not disclose suspicions to the client or third parties ("tipping off"), as this is a criminal offense under POCA.

7. Record Keeping

UK Bailiff Services Ltd will maintain records to demonstrate compliance with AML regulations. Records include:

• Client identification documents and CDD information.
• Transaction records, including payment details and correspondence.
• Suspicious activity reports and MLRO decisions.
• Staff training logs.

7.1 Retention Period

Records must be retained for at least 5 years from the end of the business relationship or transaction. Records must be stored securely and be accessible for regulatory audits.

8. Training

• All employees will receive AML training upon onboarding and annually thereafter.
• Training will cover:
  • Recognizing signs of money laundering and terrorist financing.
  • CDD and suspicious activity reporting procedures.
  • Legal obligations under UK AML laws.
• The MLRO will maintain records of training completion.

9. Risk Assessment

UK Bailiff Services Ltd will conduct an annual AML risk assessment to identify and mitigate risks specific to its operations. The assessment will consider:

• Client profiles and geographic locations.
• Types of services offered (e.g., debt recovery).
• Transaction types and payment methods.

The MLRO will update this policy based on risk assessment findings.

10. Sanctions Compliance

• UK Bailiff Services Ltd will screen clients against UK sanctions lists (e.g., HM Treasury's Consolidated List) before onboarding and during ongoing monitoring.
• Any matches will be escalated to the MLRO for further investigation and potential reporting to the Office of Financial Sanctions Implementation (OFSI).

11. Policy Review

This policy will be reviewed annually or when there are significant regulatory changes. Updates will be communicated to all employees.

12. Non-Compliance

Failure to comply with this policy may result in disciplinary action, up to and including termination. Non-compliance may also lead to legal consequences under UK law.

13. Contact

For questions or to report suspicious activity, contact the MLRO: