Last Modified: 03 October, 2024

Introduction

At Valustaff Limited (“Company” or “We”), we are committed to preventing money laundering and the financing of terrorism. This Anti-Money Laundering (AML) Policy (“Anti-Money Laundering (AML) Policy” or “Policy”) outlines our commitment to comply with UK regulations and global standards to detect, prevent, and report suspicious activities. We take our responsibility seriously to ensure that our business is not used to facilitate financial crime. 

Legal Framework

• This Policy complies with the UK’s anti-money laundering regulations, including but not limited to:
• The Proceeds of Crime Act 2002 (POCA)
• The Terrorism Act 2000
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
• The Financial Conduct Authority (FCA) rules and guidance

Objectives

Our AML Policy is designed to:

• Prevent the use of Company’s services for money laundering or terrorist financing.
• Identify, assess, and mitigate risks related to money laundering.
• Ensure proper reporting of suspicious activities to the relevant authorities.
• Maintain records of customer identification and transactions in compliance with the applicable law.

Customer Due Diligence (CDD)

We perform thorough due diligence to verify the identity of all our clients. This includes:

• Identifying and verifying the identity of clients using official documents such as passports, driving licences, and utility bills.
• Performing enhanced due diligence (EDD) for higher-risk clients, such as those from high-risk countries or politically exposed persons (PEPs).
• Ensuring ongoing monitoring of business relationships and transactions to detect and report suspicious activity.

Risk Assessment

The Company adopts a risk-based approach to AML, where the level of scrutiny varies based on the client’s risk profile. This process includes:

• Identifying potential risks based on client activity, geographic location, and transaction type.
• Implementing appropriate controls for mitigating identified risks.
• Regularly reviewing and updating our risk assessment procedures.

Reporting Suspicious Activities

Employees are required to report any suspicious activity to the company’s Money Laundering Reporting Officer (MLRO). The MLRO will:

• Investigate the report and decide whether it should be escalated to the National Crime Agency (NCA).
• Submit a Suspicious Activity Report (SAR) where necessary.
• Ensure confidentiality of the report and that no tipping-off occurs.

Training

All Company’s employees or contractors are provided with regular AML training to ensure they understand:

• The importance of AML compliance.
• How to identify suspicious transactions and behaviours.
• The reporting procedures for suspicious activity.

Monitoring and Review

This AML Policy will be reviewed and updated regularly to ensure ongoing compliance with legal requirements and best practices. The Company also conducts internal audits to monitor the effectiveness of our AML controls and procedures.

Contact Information

For further information regarding this Policy, or if you wish to report suspicious activity, please contact our Company at legal@valustaff.co.uk.