Anti-Money Laundering & Counter-Terrorist Financing Policy

Optimyze Finance (the practice), a Limited Liability Partnership, is committed to upholding its AML/CTF obligations under UK legislation. The practice has only two partners, with Manu Gupta as Managing Partner.

The MLRO must regularly review this policy (and in any case at least annually) to ensure it remains up-to-date and adequate. A written record must be kept of when the policy was last reviewed and any changes that were made.

This policy applies to all future employees and future partners of the Practice. It covers all services provided by the practice, including but not limited to accounting and advisory services.

This policy must be communicated and read by all future staff and partners as and when they are hired. A written record must be maintained to confirm all staff have read and understood this policy. If any changes are made following the annual review, these changes must also be communicated to staff and a written record maintained.

It is our policy to undertake a formal and documented practice risk assessment that will focus on the risk to the practice arising from factors including:

• Our clients
• The services we deliver
• How we deliver our services
• The countries we deliver our services in

Optimyze Finance risk assessment will be renewed on a risk-sensitive basis and in any case at least annually.

In order to comply with the Money Laundering and Terrorist Financing (Amendment)(No.2) Regulations 2022, the practice will include procedures to identify, assess and mitigate clients’ exposure to proliferation financing risks.

The Practice will document findings and implement appropriate measures to mitigate identified risks.

It is our policy to undertake CDD and ensure that evidence of identity is obtained and retained as appropriate to the risk assessment for all clients. In practice, we obtain a client’s:

• Name
• Photograph on an official document which confirms their identity (examples: passport/driving licence)
• Electronic ID
• Residential address and date of birth

It is our policy to satisfy who the practice is looking to establish a business relationship with by:

• Obtaining information on the purpose and intended nature of the business relationship
• Checking for the existence of any beneficial owners, and, if present, identify them and take reasonable measures to verify their identity
• Verifying information held on Companies House PSC register and, if there are any discrepancies with information held on the client, report directly to HMRC

The nature and extent of evidence and information obtained must reflect the level of risk the business relationship poses. Therefore the practice must perform a client risk assessment on every client to assess the level of ML and TF risk they pose. The CDD forms contained in AICPA-CIMA’s Members’ Handbook will be used.

The requirements set out above must be satisfied before a business relationship is established with the client. The practice must not establish a business relationship if we have been unable to satisfy these requirements.

The practice’s Terms of Engagement must outline the services to be provided with sufficient detail to make clear the intended nature and purpose of the business relationship, and must provide the client with the required data protection information.

The practice must ensure reliable sources of electronic ID verification are used to undertake CDD, which is free from fraud and provides sufficient assurance of the identity of the individual.

It is our policy to conduct ongoing monitoring measures, which includes:

• Scrutiny of transactions and activity undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions/activity are consistent with our knowledge of the client, the client’s business and risk profile.
• Undertaking reviews of existing client records and keeping documents or information obtained on the client up-to-date.

The degree and nature of the ongoing monitoring measures must reflect the level of risk the business relationship poses. The practice will consider whether the level of risk has changed as part of ongoing monitoring. The practice will terminate the business relationship if we have been unable to satisfy the ongoing monitoring requirements.

It is our policy to apply enhanced due diligence measures where any business relationship has been assessed as high risk in order to manage and mitigate the risk. EDD measures will be applied in addition to the standard CDD requirements.

High risk situations include:

• A high risk of ML or TF as identified in our practice risk assessment
• The client is a politically exposed person (PEP), or a family member or known close associate of a PEP
• The client is established in a high-risk third country
• Information made available by our Supervisory Authorities: AICPA-CIMA and HMRC
• A transaction is complex and unusually large, or there is an unusual pattern of transactions with no apparent economic or legal purpose
• Any other case which by its nature can present a higher risk of money laundering or terrorist financing

The enhanced due diligence measures will be undertaken by Manu Gupta and will include:

• Obtaining information on the source of funds and source of wealth of the customer and of the customer's beneficial owner
• Obtaining additional information on the intended nature of the business relationship
• Obtaining information on the reasons for the transactions
• Conducting enhanced monitoring of the business relationship by increasing the number and timing of controls applied, and selecting patterns of transactions that need further examination

We will use an electronic verification service to seek to establish whether a client is a PEP. For complex or unusual transactions, we will, as far as reasonably possible, examine the background and purpose of the transaction and increase the degree and nature of monitoring.

The practice will notify the supervisory authorities AICPA-CIMA and HMRC if there is a change in the identity of the MLRO within 14 days of the appointment.

The MLRO is responsible for:

• Monitoring the adequacy of the practice's AML/CTF systems and controls and to mitigate and manage the risk of ML and TF.
• Ensuring all future staff receive AML/CTF training as set out in Section 8.

We will ensure:

• All future staff are aware of the law relating to ML and TF, and to the requirements of data protection, which are relevant to the implementation of the Regulations.
• Provision of regular training in how to recognise and deal with transactions and other activities or situations which may be related to ML or TF.
• Maintenance of records of training sessions, including dates and attendees.

The MLRO is responsible for deciding when additional training is required or when training should be refreshed, taking into account any changes in the nature of the practice, regulatory changes, and whether any internal or external SARs have been made.

The MLRO will report if any client is engaged in ML or TF (‘suspicious activity’) by making a Suspicious Activity Report (SAR) to the National Crime Agency where required.

It is our policy to keep:

• A copy of any documents and information obtained to satisfy our CDD (including ongoing monitoring and EDD) obligations set out in this policy.
• Sufficient supporting records (consisting of the original documents or copies) in respect of a transaction to enable the transaction to be reconstructed.
• Training records as set out in Section 8.
• Suspicious activity records as set out in Section 9.

We will ensure:

• An annual review is conducted to assess the effectiveness of AML/CTF policy and procedures.
• The MLRO documents findings and implements necessary changes based on review outcomes.

It is our policy to maintain the most valid version of AML/CTF policy. The MLRO is responsible for approving and publishing the policy, the controls and procedures adopted by the practice.