This policy has been prepared by The Money Laundering Reporting Officer (MLRO) to set out the practice’s policy for complying with the UK AML/CTF regime (principally, The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, The Money Laundering and Terrorist Financing Regulations (Amendment) Regulations 2019 and the Proceeds of Crime Act 2002).
The Money Laundering Reporting Officer (MLRO) for this practice is Manu Gupta, Managing Partner. We will 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 the current and future employees & the current 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 the 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 review set out in 2.1, these changes must also be communicated to staff and a written record maintained to confirm they have read and understood the changes.
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:
Optimyze Finance risk assessment will be renewed on a risk-sensitive basis and in any case at least annually. The Practice will document findings and implement appropriate measures to mitigate identified risks.
From the most recent practice risk assessment, the key areas of risk to the practice at present are:
The practice will notify the supervisory authorities: CIMA and HMRC if there is a change in the identity of 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.
The MLRO is responsible for ensuring all the current and future staff receive AML/CTF training.
The MLRO is responsible for deciding when additional training is required or when training should be refreshed to satisfy the requirements, and when doing so must take into account at least 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. The justification as to why a SAR was or was not submitted by the MLRO to the National Crime Agency will be recorded in a confidential and separate place from the client file.
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 (including an occasional transaction that does not form part of a business relationship) which is the subject of CDD (including ongoing monitoring and EDD) to enable the transaction to be reconstructed,
that MLRO document findings and implement necessary changes based on review outcomes.
It is our policy to maintain the most valid version of AML-CTF policy and the MLRO is responsible for approving and publishing the policy, the controls and procedures adopted by the practice.
If you have any questions regarding our AML policy, please contact us connect@optimyze.finance
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