Eminence Bookkeeping take a zero-tolerance approach to being involved in illegal/illicit activity and will fully comply with all relevant sections of the Money Laundering Regulations 2017 (as amended by the MLR 2019), the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000 (TACT).

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All partners and employees of the firm are under an obligation and duty to comply with the above. Any related procedures aim to help partners and staff fulfil these responsibilities.

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• Failure to fulfil these responsibilities may result in disciplinary action and may also result in criminal sanctions for the staff involved.

• Breaches may also be reported to our AML Supervisor (ICB) which may result in professional disciplinary action.

• Furthermore, a report may also have to be made to the NCA or other law enforcement agencies, which may result in a criminal investigation.

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Responsibilities under relevant legislation include:

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Money Laundering Regulations 2017 / 2019:

• Risk Based Assessment

• Customer Due Diligence, including ID&V requirements, assessing Source of Wealth, and application of KYC information

  • Enhanced Due Diligence & Ongoing Monitoring(incl. definition and treatment of PEPs

• MLRO Responsibilities, SAR Reporting, Tipping Off, Police Orders

• Quality Assurance

• AML Record Keeping

• AML Training

• Compliance with International Sanctions Requirements

 

Proceeds of Crime Act 2002 / Terrorism Act 2000:

MLRO responsibilities, Suspicious Activity Reporting, Tipping Off & Police Orders

 

Key responsibilities of staff therefore include (but are not limited to):

• Conducting an adequate risk assessment and appropriate due diligence (CDD) on clients and transactions, including PEP and sanctions checking.

• Monitoring all clients/transactions on an ongoing basis for potential money laundering or terrorist financing activity.

• Reporting any suspicious activity in respect of client or transactions to the MLRO in accordance with the firms SAR (suspicious activity reporting) procedure.

• Avoiding discussing any potential or actual SARs with clients or any third parties (“Tipping off”)

• Referring any Police/Law Enforcement queries or requests to the MLRO.

• Undertaking any AML-related training provided by the Firm.

• Keeping appropriate records of all AML related activity

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For more information, please visit www.gov.uk or follow the links below.

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POCA 2002

Proceeds of Crime Act 2002 (legislation.gov.uk)

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Money Laundering Regulations 2017

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (legislation.gov.uk)