Last updated: 26 July 2026
1. Our commitment
We operate a risk-based anti-money-laundering (AML) and counter-terrorist-financing (CTF) programme designed to meet the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000, UK sanctions legislation and JMLSG guidance.
2. Governance
We appoint a Money Laundering Reporting Officer (MLRO) with responsibility for the AML/CTF framework, suspicious activity reporting and liaison with the National Crime Agency. Senior management approves our written risk assessment and policies and reviews them at least annually.
3. Customer due diligence
- We identify and verify every customer before establishing a business relationship or executing an occasional transaction.
- We collect government-issued photo identification, date of birth and address details.
- We record the purpose of the transfer, the relationship to the beneficiary and, where applicable, the source of funds.
- Enhanced due diligence applies to higher-value transfers, cash-intensive activity, politically exposed persons and high-risk jurisdictions.
- Ongoing monitoring keeps records current throughout the relationship.
4. Sanctions and PEP screening
Senders and beneficiaries are screened against consolidated sanctions and politically-exposed-person data, including UK OFSI, UN, EU and OFAC sources. Potential matches are held and reviewed by a human before any funds move. Confirmed matches are blocked and reported as required.
5. Transaction monitoring
Automated rules flag velocity, structuring (multiple sub-threshold payments), unusual corridors, aggregation across a sender's history and cash-specific typologies. Flagged activity creates a compliance case for review.
6. Cash controls
Where cash is accepted, it is logged at the point of receipt against a branch till, reconciled daily against the ledger and subject to cash-specific thresholds and enhanced checks.
7. Suspicious activity reporting
Staff must escalate any suspicion to the MLRO immediately. The MLRO assesses each report and, where suspicion remains, submits a Suspicious Activity Report to the National Crime Agency. We do not tip off customers about reports, as required by law.
8. Record keeping
Identification, transaction and compliance records are retained for five years after the end of the relationship or transaction, then securely deleted or anonymised.
9. Training
All staff and agents receive AML/CTF and sanctions training on appointment and at least annually, with records kept for inspection.
10. Prohibited activity
We refuse transfers connected with money laundering, terrorist financing, fraud, sanctioned parties, illegal gambling or any unlawful purpose, and we may delay, refuse or freeze a transfer while checks are carried out.