Policy Statement and Procedures
These are the Anti-Money Laundering (ALM) Policy and Procedures adopted by Klapton Insurance Company in compliance with Klapton’s internal policies and regulatory obligations and The business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.
To these ends:
- The identities of all new and existing clients will be verified to a reasonable level of certainty
- A risk-based approach will be taken to the monitoring of client tax and accounting affairs
- Any suspicious activity will be reported, and all AML activities recorded
- Danny Joffe (in consultation with the board of directors) will act as the Money Laundering Reporting Officer (MLRO) to coordinate the money laundering policies and procedures of the business.
- All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.
- The following form contains the names and signatures of members of the staff that have read the anti-Money Laundering policy and procedures of this practice
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ANTI-MONEY LAUNDERING PROCEDURES FOR KLAPTON INSURANCE COMPANY
- CUSTOMER DUE DILIGENCE
The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients are verified to a reasonable level of certainty. This will include all individual clients, all directors and shareholders with a stake holding of 25% or more of client companies, all partners of client partnerships, and every board member of client charities. Identities will be verified either online or face-to face or by a combination of both.
The following documentation may be presented by the prospective client, partner or third party:
Any government issued document that provides the date of birth, NI or Tax number or other such government identifier.
- Other forms of identity confirmation, such as evidence of a long standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty.
- Registration certificates of the juristic entity.
- Passport or other acceptable identification documents of shareholders and the directors of the entity.
- Proof of bank accounts of the juristic entity.
If the business fails to verify the identity of a client with reasonable certainty it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.
- RISK ASSESSMENT AND ONGOING MONITORING
The business shall take a risk-based approach in monitoring the financial activities of its clients.
The business will actively not accept high-risk clients that are identified as follows:
- Clients with businesses that handle large amount of cash (i.e. involving €15,000 euros or more per transaction, or the sterling equivalent) or complex unusually large transactions.
- Clients with larger one-off transactions, or a number of transactions carried out by the same customer within a short space of time.
- Clients with complex business ownership structures with the potential to conceal underlying beneficiaries.
- Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organised crime or drug production/distribution.
- Situations where the source of funds cannot be easily verified.
- Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
- Money sent to or received from areas known to have high levels of criminality or terrorist activity.
The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date or information held evidencing the customer’s identity are kept up to date.
The following are examples of changes in a client’s situation that may be considered suspicious:
- A sudden increase in business from an existing customer;
- Uncharacteristic transactions which are not in keeping with the customer’s known activities;
- Peaks of activity at particular locations or at particular times;
- Unfamiliar or untypical types of customer or transaction.
Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.
No action need be taken if there is no cause for suspicion.
- INTERNAL CONTROLS AND COMMUNICATION
Internal controls and Communication are not applicable as the business only has one person involved in client compliance.
- MONITORING AND MANAGING COMPLIANCE
The MLRO will regularly monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:
- client identity verification;
- reporting suspicious transactions;
- record keeping.
The MLRO will also monitor any developments in the MLR and the requirements of the MLR supervisory body. Changes will be made to the AML policies and procedures of the business when appropriate to ensure compliance.
- SUSPICIOUS ACTIVITY REPORTING
A Suspicious Activity Report (SAR) will be made to the relevant authority as soon as the knowledge or suspicion that criminal proceeds exist arises.
The MLRO will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.
Records of all identity checks will be maintained for up to 5 years after the termination of the business relationship or 5 years from the date when the transaction was completed. The business will ensure that all documents, data or information held in evidence of customer identity are kept up to date.
All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.
The training of staff is not applicable as the business only has one employee involved in ML compliance who is also the MLRO.
All affected employees are provided with training that explains the concept of money laundering and any regulation which may affect such staff.
All affected employees should be trained on their responsibilities in relation to money laundering transactions.