top of page
Contact Us Header Banner_06.png

Anti-Money Laundering (AML) Policy

1. Introduction and Commitment

More4Business Ltd is committed to preventing its services from being used for money laundering, terrorist financing, and other financial crime. This policy outlines the procedures we follow to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 (POCA), and the relevant guidelines from the Financial Conduct Authority (FCA).

 

2. Designated Roles and Responsibilities

A. Senior Management

Senior Management is responsible for:

  • Approving the firm's AML policies, procedures, and controls.

  • Ensuring the firm has adequate resources to manage AML risks.

B. Money Laundering Reporting Officer (MLRO)

  • Designated MLRO: Oliver Beamer, Sales Director

  • Contact: oliver@more4business.co.uk or 07798768600

  • Responsibilities: Receiving internal suspicious activity reports (SARs), determining whether to report to the National Crime Agency (NCA), overseeing AML training, and acting as the primary point of contact for regulatory bodies regarding AML.

 

3. Risk-Based Approach (RBA)

We adopt a Risk-Based Approach to identify, assess, and understand the money laundering and terrorist financing risks to which we are exposed.

A. Risk Assessment

Our formal, documented risk assessment considers factors including:

  • Client Risk: Type of customer (e.g., high-risk jurisdictions, complex corporate structures).

  • Product/Service Risk: The type of finance provided (e.g., large volume transactions, speed of transaction).

  • Geographic Risk: Countries where the clients or funds originate.

  • Delivery Channel Risk: Reliance on third-party intermediaries (lenders/introducers).

B. Risk Mitigation

The findings of the risk assessment determine the level of Customer Due Diligence (CDD) applied to each business relationship.

 

4. Customer Due Diligence (CDD) / Know Your Customer (KYC)

We will not establish a business relationship or carry out an occasional transaction without completing appropriate CDD.

A. Standard Customer Due Diligence (SCDD)

For all clients, we will:

  1. Verify the Identity of the customer (the company).

  2. Verify the Identity of the beneficial owners and persons exercising control (POECs) who hold typically 25% or more of the company.

  3. Obtain Information on the purpose and intended nature of the business relationship (i.e., the reason for the loan/finance).

Verification Documentation (Examples):

  • Company: Certificate of Incorporation, company search/registry extract, or latest accounts.

  • Individuals (Directors/POECs): Passport/Driving Licence (Photo ID), utility bill/bank statement (Proof of Address).

B. Simplified Due Diligence (SDD)

SDD may be applied only where the risk is assessed as low, for example, for certain public authorities or FCA-regulated firms.

C. Enhanced Due Diligence (EDD)

EDD will be applied in high-risk situations, including but not limited to:

  • Clients located in High-Risk Third Countries (as identified by HMT).

  • Clients with overly complex or opaque ownership structures.

  • Clients who are, or are associated with, Politically Exposed Persons (PEPs).

  • Any relationship where suspicion of money laundering is raised.

EDD Measures (Examples):

  • Obtaining additional information on the source of funds/wealth.

  • Requiring Senior Management approval to establish or continue the relationship.

  • Increased ongoing monitoring.

 

5. Ongoing Monitoring

We continuously monitor our business relationships to ensure that:

  • Transactions are consistent with our knowledge of the customer, their business, and their risk profile.

  • Documentation and information (e.g., changes in directors or beneficial ownership) remain up-to-date and relevant.

 

6. Reporting Suspicious Activity

A. Internal Reporting

Any employee who knows or suspects money laundering or terrorist financing activity must report it immediately to the MLRO by completing an Internal SAR Form.

  • Employees must not "tip off" the customer or any third party that a report has been made or that an investigation is underway.

  • All reports are treated confidentially.

 

B. External Reporting (SARs)

The MLRO will:

  • Evaluate all internal SARs.

  • Submit an external Suspicious Activity Report (SAR) to the National Crime Agency (NCA) via the SAR online system if they know, suspect, or have reasonable grounds to know or suspect money laundering or terrorist financing.

 

7. Record Keeping

We will maintain records of all CDD measures taken, supporting evidence, and all transactions for a minimum period of five (5) years after the business relationship ends or the last transaction is executed, as required by the MLR 2017.

 

8. Training

All relevant employees, including those involved in client onboarding, transaction processing, and compliance, will receive mandatory AML training on an ongoing basis, at least annually.

The training will cover:

  • The current law and the firm’s procedures.

  • Employee's personal legal liability.

  • How to recognise and handle transactions and circumstances that may be related to money laundering.

  • The internal reporting process.

 

Policy Review Date: 2nd December 2025.

bottom of page