MONEY LAUNDERING POLICY

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (in force from 26 June 2017) and the Proceeds of Crime Act 2002 impose a number of obligations on law firms in the United Kingdom as part of the UK Government's measures to combat money laundering and the financing of terrorism.

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The combined effect of this legislation is to provide a stringent and comprehensive system of client identification procedures, record keeping, and mandatory reporting.

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When first taking your instructions, we are required to identify both our client and (if relevant) the ultimate beneficial owner of our client, and to verify that identity in a number of ways. We may need your assistance to satisfy these requirements. Without compliance with these obligations, we will not be able to act for you.

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To ensure compliance with the law and to ensure we know and fully understand the identity and structures of our clients we have robust anti-money laundering policies and procedures in place.

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Client and Matter Due Diligence

We conduct due diligence enquiries on all new clients to establish and verify our clients’ identity and the identity of any beneficial owners. We may also undertake such enquiries on anyone instructing us on behalf of, but who may not be our clients. We cannot act if sufficient information is not provided.

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We generally require to see original documentation. We use third-party providers who search external electronic databases as part of this diligence process.

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We also undertake risk assessments for all new matters for existing clients.

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On-going Monitoring

We undertake on-going monitoring of all existing clients (which may require you to provide us with updated proof of identity documentation).

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Source of Wealth and Funds

We are required to know the source of funds involved in the transactions we are undertaking. We will also have to enquire about the source of your wealth. We accept no responsibility for any transactions being delayed while this information is awaited.

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Tipping off

We must report to the National Crime Agency and other relevant authorities any suspicion or knowledge regarding money laundering or the proceeds of crime. We are not permitted to notify you of the fact that such reports have been made.

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Confidentiality

Our duties to report to the National Crime Agency may take priority over any duty to keep your information and the detail of your transactions confidential.