Last updated: 7 August 2026
1. Who can use this
Anyone connected to our business — employees, branch and payout agents, contractors, suppliers, customers or former staff — can raise a concern about wrongdoing. You do not need proof, and you do not need to be certain. A reasonable, honestly held suspicion is enough.
2. What to report
- Money laundering, terrorist financing, or sanctions evasion.
- Fraud, theft, or misuse of customer or company funds.
- Bribery, kickbacks, or undisclosed conflicts of interest.
- Falsifying records, receipts, identity documents or reconciliations.
- Treating customers unfairly, or pressure to bypass identity or compliance checks.
- Any breach of our regulatory obligations or of the law.
If you are a customer unhappy with the service you received, use our complaints process instead — it will get you a faster answer.
3. How to raise a concern
- Email the MLRO / Whistleblowers' Champion: compliance@sarafiasif.com — write "Speak Up" in the subject line.
- In writing: marked "Private & Confidential — Whistleblowing" and addressed to the MLRO at our registered office (address available on request).
- Verbally: ask any manager to arrange a private meeting with the MLRO. We will make a written record and give you a copy.
If your concern is about the MLRO, or you do not feel able to raise it internally, report it directly to the FCA (section 6).
4. Confidentiality and anonymity
We keep your identity confidential and share it only where we are legally required to, or with your consent. You may report anonymously, though this can limit how far we can investigate and means we cannot update you on the outcome.
5. Protection from retaliation
Victimising, dismissing or disadvantaging someone for raising a concern in good faith is a disciplinary matter and, for qualifying disclosures, is unlawful under the Public Interest Disclosure Act 1998. You are protected even if the concern turns out to be mistaken, provided you raised it honestly. Any clause in a contract or settlement agreement that purports to stop you making a protected disclosure — including to the FCA — is void and we will not seek to rely on one.
6. Reporting to the regulator
You can contact the FCA directly at any time; you do not have to tell us first.
- FCA whistleblowing line: 020 7066 9200
- Email: whistle@fca.org.uk
- Guidance: fca.org.uk/firms/whistleblowing
Suspected money laundering can also be reported to the National Crime Agency, and fraud to Action Fraud on 0300 123 2040.
7. What happens next
- We acknowledge your report, usually within five business days where we have your contact details.
- The MLRO assesses it and decides whether an investigation, an internal suspicious activity report, or a report to a regulator or the police is needed.
- We record every concern, the assessment and the outcome, and senior management reviews the log at least annually.
- Where we can, we tell you the outcome, while respecting the confidentiality and employment rights of anyone else involved.