Anti Money Laundering Policy

1. Policy scope

This is a mandatory policy which applies to all employees, Regional and Divisional Directors, Regional Partners, CFO Centre CFOs, directors and contractors of The FD Centre Limited trading as The CFO Centre (the “CFO Centre”).

This policy is designed to ensure compliance with UK anti-money laundering (AML) and counter-terrorist financing (CTF) legislation (AML Legislation), in particular, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (SI 2017/692) (MLR 2017), Proceeds of Crime Act 2002 (POCA) and Terrorism Act 2000 (TACT). The policy takes into account the CCAB AML guidance approved by HM Treasury (CCAB Guidance).

Click to review CCAB AML guidance approved by HM Treasury.

Failure to adhere to the policy may be treated as a serious disciplinary issue and/or material breach of your services (or other) contract (where applicable). In addition, if you fail to comply with the policy, you may risk breaching the requirements of the MLR 2017 and may potentially expose yourself and the CFO Centre to the risk of criminal prosecution for offences punishable by an unlimited fine and up to two years’ imprisonment.

2. Ethical Obligations

As a portfolio CFO working through the CFO Centre, it is important to remember that, while the CFO Centre acts as the entity contracting with the client, each CFO operates as an independent subcontractor to the CFO Centre, and are therefore still bound by the code of ethics set by their professional body (e.g. ICAEW, CIMA, ACA). Each and every CFO therefore continues to bear full responsibility for their own ethical obligations. This includes for example actively participating in client due diligence for the purposes of this Policy.

3. Key Responsibilities

This policy is designed to help keep you and CFO Centre compliant with the AML Legislation.

The CFO Centre’s Legal and Compliance Team play a major role in ensuring compliance by carrying out checks on all new clients and obtaining any supporting documents required to ensure compliance with the AML Legislation.

CFOs providing services to CFO Centre clients are required to assist the Legal and Compliance Team in conduct an AML and Terrorist Financing Risk Assessment for each engagement before the CFO Centre raises its first invoice to the client.

The assessment involves a standard template split into two sections. The first section is a KYC form with around 8 questions to help the compliance team gain an understanding of the engagement with the client, the second section is a Risk Assessment with approximately 10 questions, categorising the risk as High, Medium, or Low along with a KYC form. Most engagements are low risk, with any medium or high risks referred to the Money Laundering Reporting Officer (MLRO).

It is important to note that the risk assessment is the very start of the AML and CTF journey.

Once the client has been onboarded by the Legal and Compliance Team, responsibility for ensuring ongoing compliance with the AML Legislation passes to the CFO involved in the relevant client relationship who are responsible for:

• Reviewing and checking that the risk assessment is accurate and comprehensive and making themselves available for periodic check-in calls with the Legal and Compliance Team after 3 months from the date of the initial risk assessment.
• Being vigilant of any unusual activity.
• Reporting changes or inconsistencies in a client’s source of funds. Undertaking ongoing monitoring of the client.

It is crucial that if you have any concerns or suspicions regarding a client you are working with (whether about the client or a third party) that these are reported to money laundering reporting officer (MLRO) immediately.

CFO Centre has appointed Zoe Wilson Adv.Cert (AML) its internal Compliance Officer, responsible for the day-to-day operation of this policy. The Compliance Officer works closely with the MLRO, to manage all aspects of the company’s AML-CTF compliance programme.

4. Money Laundering

What is money laundering?

Money laundering is the process through which the proceeds of crime (so-called dirty money) are processed and converted into assets that appear to have a legitimate origin.

In the UK it is an offence under POCA to process, acquire, use or possess the proceeds of crime where you know or suspect you are dealing with criminal proceeds. It is also an offence to knowingly get involved in arrangements which help someone else acquire the proceeds of crime. These are serious offences which are punishable by up to 14 years in prison.

There are three primary offences of money laundering in the UK:

• Concealing, disguising, converting, transferring or removing from the UK criminal property.
• Entering into or becoming concerned in an arrangement which a person knows or suspects facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person.
• The acquisition, use or possession of criminal property.

“Criminal property” is defined widely under POCA as a person’s benefit from criminal conduct.

It is not necessary to have actual knowledge that a party is engaged in money laundering; suspicion still requires you to act. Ignorance is no defence. The test is whether you had reasonable grounds for knowing or suspecting money laundering. For example: a CFO notices unusual large cash deposits into a client’s account that don’t align with the business’s sales and receives vague explanations from the client. While the CFO has no concrete proof of wrongdoing, these inconsistencies raise reasonable suspicion of money laundering. Under POCA, the CFO must report this internally to the CFO Centre’s MLRO, as failing to act could result in personal liability for facilitating money laundering.

Similar offences relating to the financing of terrorism are created under TACT.

Stages of money laundering

Money laundering can be categorised into three stages:

• Placement: the launderer introduces their illegal funds into the financial system. This can be done by breaking up large amounts of cash into smaller sums (Smurfing) which are less conspicuous and can be deposited into a bank account and then collected and deposited in different accounts at other locations.
• For example: A client uses “smurfing” by breaking down large sums of illicit cash into smaller deposits under the reporting threshold (e.g., £9,000) and deposits them across multiple bank accounts or branches to avoid detection. Layering: the launderer engages in a series of conversions or movements of the funds to distance them from their source. In some instances, the launderer might disguise the transfers as payments for goods or services, giving them a legitimate appearance.
• For example: The client creates false invoices for non-existent goods or services, claiming the payments are legitimate business expenses, and routes the money through offshore entities. Integration: the funds re-enter the legitimate economy, for example, the launderer may choose to invest the funds into real estate, luxury assets, or a business venture.
• For example: The client invests the funds into a legitimate-looking business venture or startup, using it as a front for further money laundering or to generate legitimate returns.

What is suspicion?

The AML Legislation does not define suspicion. However leading case law provides that suspicion requires “a degree of satisfaction not necessarily amounting to belief but at least extending beyond speculation as to whether an event has occurred or not”. In the leading case of R v Da Silva [2006] EWCA Crim 1654, the Court of Appeal provided the definition of “a possibility, which is more than fanciful, that the relevant facts exist”.

This is a low threshold to satisfy so you should always be cautious when considering whether a suspicion may exist.

Our obligations to be vigilant for money laundering extend beyond assessing our own client and include third parties of the client.

There is no exhaustive list of issues which may trigger a suspicion. However, the following factors may trigger concerns:

• Discrepancies between the client’s presented source of funds or wealth (e.g., claiming wealth from a “family business”) and the actual reality. Overly complex or opaque legal structures (e.g. a client operates through multiple shell companies registered in offshore jurisdictions with no clear business activity or beneficial ownership).
• If the transaction appears to have no purpose (e.g. a client insists on making an unusually large payment to an unrelated third-party account without explaining why it is necessary).
• If the client is pursuing loss-making transactions that lack commercial rationale (e.g. the client invests in a failing business or overpays significantly for goods or services with no expectation of financial gain).
• If the client has been secretive or deceptive (for example, unwilling to provide client due diligence documents, citing “confidentiality” reasons).
• Receipt of unexpected payments from third parties (e.g. funds are are deposited into the client’s account from an unknown individual or company)
• Offers of making payments in cash. CFO Centre’s policy is not to accept cash payments either in respect of fees or for the purposes of a transaction (the client proposes paying a significant invoice in cash, claiming it is “easier” or “faster”).

Everyone has a responsibility to be alive to suspicious activities. You must be vigilant to ensure that you do not facilitate money laundering either by clients or third parties.

Suspicious activity reporting

A suspicious activity report (SAR) is a report to law enforcement relating to possible money laundering or terrorist financing. You are legally required to make a SAR where you find out or come to know or suspect that a person, whether a client or a third party, might be engaged in money laundering or terrorist financing.

This requirement applies to all persons to whom this policy applies to including all CFOs providing services on behalf of the CFO Centre.

Failure to make an internal SAR where you know or suspect money laundering or terrorist financing is a criminal offence and may result in a fine or a prison sentence of up to five years.

Therefore, you must ensure that you stay alert to suspicious activity on the part of a client or third party and that you do not turn away from unusual or questionable facts or conduct in a client relationship. This is because where there are reasonable grounds to suspect money laundering or terrorist financing, you could also be at risk of committing a criminal offence, even where you did not develop a suspicion at the time.

In the event of encountering suspicious activities related to money laundering or tax evasion (not tax avoidance), report them to the Money Laundering Reporting Officer in the first instance. If they are unavailable, please report them to the CFO Centre’s Compliance Officer. Do not disclose suspicions to the client or take actions that may alert them, as tipping off is a separate offence. The MLRO will assess the situation, correspond with the National Crime Agency, and either authorise the continuation of the engagement or allow withdrawal from the client.

By making an internal report in this way, you will have discharged your duties under the AML Legislation; it will then be MLRO’s duty to consider whether an external disclosure should be made to the relevant authorities. Where you make an internal SAR, working with our Legal and Compliance Team you must also apply enhanced client due diligence (EDD) measures to the client. This might mean refreshing the information that we hold about them, or gathering more detailed information. The steps we take to apply EDD will be informed by our risk rating of the client, which, if we suspect money laundering, is likely to be “high” in any event. Reports can be made by email to [email protected]. The MLRO will contact you shortly after receipt of the form.

You should ensure that any report is made confidentially and that you do not discuss this with anyone else, in particular, your client or another external party. This is to ensure that you do not commit the offence of tipping off (see section below).

If you have any concerns about the origins of funds you must also share these with the MLRO.

Tipping off

A criminal offence is committed where all of the following apply:

• A SAR has been made in the course of business in the regulated sector (in our case the provision of accountancy services).
• A person discloses that the SAR has been made.
• That disclosure is likely to prejudice any investigation that might be conducted as a result of the SAR.

Real Life Scenario of Accidental Tipping Off

A CFO at a client company raises a Suspicious Activity Report (SAR) with the CFO Centre’s MLRO after noticing unexplained large payments from offshore accounts. The MLRO, following protocol, files a SAR with the National Crime Agency (NCA).

Shortly after, during a routine discussion about cash flow, the CFO casually asks the client, “Can you clarify those offshore payments? We’ve had to flag them for compliance checks.”

The client, sensing scrutiny, quickly closes the offshore accounts and halts further transactions. This action directly prejudices the investigation by concealing the suspicious activity.

A person found guilty of tipping off is liable for a fine and up to two years’ imprisonment.

You are at risk of committing a criminal offence once a suspicion has been raised (whether or internally or externally) and you must therefore take great care when speaking with a client, or any other person, in these circumstances.

5. Obligations under MLR 2017 and Client Due Diligence (CDD) Obligations

CDD and ongoing due diligence must be undertaken on all new clients applying a risk-based approach. Your primary role may not directly entail establishing beneficial ownership, but it is crucial to recognise that the failure to obtain this information could hinder client engagement. We request your cooperation and assistance where necessary to support our Legal and Compliance Team in fulfilling the requirements related to beneficial ownership identification during the client onboarding process. This means that the CFO Centre and/or CFO must:

The MLR 2017 impose obligations on CFO Centre and CFO to:

Obligation under MLR 2017: Take appropriate steps to identify and assess the risks of money laundering and terrorist financing to which our business is subject, taking into account the nature and size of the business and to document these in a firm-wide risk assessment.
Responsible Party: CFO Centre and CFO
How is this implemented: The CFO Centre conducts firm-wide risk assessments, but these rely heavily on CFOs identifying and reporting client-specific risks, such as unusual transactions or complex ownership structures.

Obligation under MLR 2017: Establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing identified in our firm-wide risk assessment.
Responsible Party: CFO Centre
How is this implemented: The CFO Centre implements controls such as requiring enhanced due diligence (EDD) for clients from high-risk jurisdictions, , and conducting regular reviews of policies to ensure compliance with new regulations.

Obligation under MLR 2017: Carry out screening of relevant employees, both before the appointment is made and during the appointment.
Responsible Party: CFO Centre
How is this implemented: Before hiring a new employee or bringing on a new CFO, the CFO Centre screens for criminal records, checks professional qualifications, and verifies that the individual has a current membership to one of the major accountancy institutions.

Obligation under MLR 2017: Conduct an independent audit to examine and evaluate the adequacy and effectiveness of our AML and CTF policies, controls and procedures.
Responsible Party: CFO Centre
How is this implemented: Our Compliance Officer and MLRO periodically assess the effectiveness of our AML policies and carry out spot checks on our KYC/CDD documentation.

Obligation under MLR 2017: Undertake due diligence on our clients applying a risk-based approach.
Responsible Party: CFO Centre and CFO
How is this implemented: The CFO Centre uses a risk-based approach where clients from higher-risk sectors or countries are subject to more detailed checks.

Obligation under MLR 2017: Establish and monitor the purpose and nature of the business relationship and undertake ongoing monitoring of those client relationships, which includes detection of unusual or suspicious transactions.
Responsible Party: CFO Centre and CFO
How is this implemented: The Regional Director/Partner and CFO will establish the purpose of the relationship, this will be recorded on the risk assessment undertaken by the CFO for the Compliance Team to review. Ongoing monitoring also involves the CFO reviewing a client’s transaction patterns regularly. For example, if a client who normally handles small transactions suddenly processes large sums, this triggers further investigation to ensure the transactions are legitimate.

Obligation under MLR 2017: Appoint individual(s) responsible for AML and CTF systems and for managing CFO Centre’s relationship with, and making reports to, the National Crime Agency (NCA)
Responsible Party: CFO Centre
How is this implemented: The CFO Centre designates a Compliance Officer to oversee all AML/CTF activities, ensuring timely submission of Suspicious Activity Reports (SARs) to the NCA and liaising with them when necessary.

Obligation under MLR 2017: Preserve due diligence and other related AML and CTF compliance records.
Responsible Party: CFO Centre and CFO
How is this implemented: All records of client due diligence, such as identification documents, client transaction logs, and SARs, are securely stored for at least five years after the end of a business relationship, in compliance with regulatory requirements.

Obligation under MLR 2017: Ensure that all relevant staff understand the importance of taking appropriate AML measures, and are made aware of the law relating to AML and CTF, including through training in how to recognise and deal with transactions and other activities or situations which may be related to money laundering or terrorist financing.
Responsible Party: CFO Centre
How is this implemented: The CFO Centre provides annual AML training for all staff, including how to identify red flags such as suspicious patterns in client transactions or reluctance to provide identification, and ensures staff understand the legal obligations to report suspicions without tipping off clients.

Obligation under MLR 2017: If CFO Centre has not undertaken any work for a client for 6 months the status of the client record will automatically change on the CFO Centre’s systems from “active” to “lapsed”. A lapsed client can be made active without CDD being refreshed, provided that no material changes have taken place within the client since the client lapsed, and provided that no more than 3 years has passed since the client lapsed. The CFO Centre’s Compliance Officer will walk you through this process.
Responsible Party: CFO Centre
How is this implemented: The Finance team will lapse all clients who have not billed within a 6 month period. If the client reengages then new paperwork will be sent to the client, if the ownership has not changed since we last engaged we will use previous documents obtained. On the occasion where the ownership does change in the time we reengage then new documents will be requested from the client and put through the standard client check. A further risk assessment will also be requested from the CFO to assess the risk in the business since reengaging.

(Note: The CFO Centre’s AML Onboarding Process is set out in Annex B).

6. Enhanced due diligence

Enhanced due diligence (EDD) is the process of applying additional measures to gain a better understanding of the background, ownership and financial profile of the client. EDD must be applied at the client onboarding stage and throughout the business relationship where a client or beneficial owner poses a heightened financial crime or reputational risk to CFO Centre.

EDD must be applied if one or more of the following risk factors is identified:

• There is knowledge of, or sufficient grounds to suspect, money laundering, terrorist financing or other financial crime.
• The client or beneficial owner is established or resident in a high or very high-risk country.
• The client or beneficial owner is subject to sanctions.
• The client or beneficial owner is, or is a family member or close associate of, a politically exposed person (PEP).
• The client or representative of the client has not been met in person or though a video call.
• The client operates in a high-risk sector.
• The client or beneficial owner is subject to severe adverse media (for example, allegations of criminality).
• Unusual circumstances associated with the client, beneficial owner, wider business relationship or transaction.
• The transaction or pattern of transactions is unusually large, complex or the transaction has no apparent economic or legal purpose.
• The client’s structure is complex or unusual for the client type and for which there is no commercial rationale.
• Any other situation that presents a heightened money laundering, terrorist financing or reputational risk to CFO Centre.

EDD measures must be tailored to the circumstances and applied to address the specific high-risk indicators identified during the risk assessment. There are several EDD measures which may be applied, including:

• Obtaining additional information about the client, its corporate structure and any beneficial owners from independent sources.
• Reducing the threshold for beneficial ownership and conducting due diligence on any beneficial owners with an interest of 10% or more.
• Obtaining additional information relating to the source of wealth of the client and beneficial owner.
• Obtaining additional information and supporting documents in respect of the source of funds to be used in a transaction.
• Obtaining additional information relating to the purpose and intended nature of the business relationship.
• Conducting further research and adverse media screening in relation to the client or beneficial owner.
• Conducting additional screening of persons associated with the client (such as directors and instructing persons) and known associates of the beneficial owner.
• Conducting enhanced ongoing monitoring of the business relationship.

7. Politically exposed persons

A PEP is an individual, or family member or close associate of that individual, who is, or has been in the preceding 12 months, entrusted with a prominent public function by an international body or a state.

Specific EDD measures must be applied when dealing with a client who is a PEP, or who has a beneficial owner who is a PEP. Additional information must be obtained on:

• The PEP, why they have been classed as a PEP and their business interests.
• The purpose and intended nature of the business relationship.
• Their source of wealth and for transactional matters, their source of funds.

Note: The CFO Centre uses Smart Search, a screening service that helps identify whether a client or beneficial owner is a PEP by cross-referencing their details with a global database of PEPs. We also request our CFOs to consider a beneficial owners/directors PEP status in our client risk assessment. However, we also require our CFOs to inform us directly if they suspect that they are working with a PEP, as this helps ensure that the appropriate EDD steps are taken.

8. Timing of client due diligence
9. Evidence of identity must be obtained when establishing a new client relationship and should be collected at the point of contracting. This information will be requested by the Legal and Compliance Team as part of the paperwork process with the client. CFOs are not permitted to commence any work before Customer Due Diligence (CDD) has been completed, unless specific authority has been granted by the MLRO. Requirement to exit a client

Where CDD cannot be applied to any client, the AML Legislation requires that no relationship may be established with that client.

If circumstances arise where you believe that CDD cannot be carried out as required, you must therefore cease all work for and communications with the client and report the circumstances to the MLRO immediately.

If you have developed knowledge, concerns or suspicions that the client may be engaged in money laundering, you must also make an internal report to the MLRO as set out above.

10. Requirement to report material discrepancies in registers

When conducting CDD on companies and partnerships registered on the UK register of people with significant control (PSC Register), The Legal and Compliance Team will obtain proof of registration.

If any material discrepancies are identified between the beneficial ownership information on the PSC Register and information obtained from other sources (including the client), this may trigger an obligation to report the discrepancy to Companies House in the UK.

e.g. upon reviewing the PSC Register, the Legal and Compliance team notices that the beneficial owner listed is an individual who is no longer associated with client. The client’s Articles of Association and the client’s own records indicate that a different individual, who holds 30% of the shares, should be listed as the beneficial owner. This discrepancy raises concerns regarding the accuracy of the ownership details and must be reported to Companies House.

11. Client opening process

All CFOs are required to assist the Legal and Compliance Team in carrying out a client risk assessment for each engagement prior to the start of any client engagement, taking into account (for example):

• The type of client (sole trader, partnership, limited company and so on).
• The nature of the client’s business (e.g. retail business or tech start up)
• The jurisdiction in which the client is registered and operates (e.g. registered in the UK and operates across the EU)
• Public information available (e.g. company filings, financial statements, or public records)
• Source of Funds (e.g. Personal savings, business revenue, or investments).
• % of Cash Trading. E.g. regular receipts of cash
• Client Contact and Introduction. E.g., referred by a mutual contact or introduced through a business network.
• External Regulation (e.g. subject to financial authority oversight)
• The involvement of any PEP (e.g. a politically exposed person with ties to a foreign government).
• Any sanctions issues (e.g. our Legal and Compliance Team will establish whether the client is listed on a sanctions list or involved in prohibited business activities).

The above list is not definitive and each factor depends on the individual circumstances of the client. For a more comprehensive list, please refer to the Client Risk Assessment document or reach out to the CFO Centre’s Compliance Officer.

As noted above, the CDD conducted at client opening is only the start of the CDD journey. Once the client is opened, the CFO is responsible for:

• Being vigilant of any unusual activity.
• Scrutinising the source of a client’s funds.
• Undertaking ongoing monitoring of the client.

Communicating any changes in risk to the Legal and Compliance Team (note that periodic check-ins may be scheduled, and you must cooperate by providing status updates to the Legal and Compliance Team).

12. Sanctions

The CDD undertaken by the Legal and Compliance Team will identify if the new client or associated individual is subject to any sanctions. If any sanctions issues are identified, the Compliance Officer and/or MLRO will contact the CFO to discuss next steps.

We do not do business with clients or entities from sanctioned countries or regions, and we comply fully with all applicable sanctions regulations. This includes ensuring that no transactions or partnerships involve individuals, organisations, or countries subject to UK or international sanctions.

13. Referrals

If the client is a current client of one of the CFO Centres sister businesses, The Legal and Compliance Team is unable to rely on any CDD undertaken by those entities and must undertake their own. This is because those entities may be operating in circumstances with lower AML and CTF regulatory requirements than the CFO Centre.

Similarly, CFO Centre will not accept requests from third parties (including sister businesses) who wish to rely on the CDD undertaken by CFO Centre.

14. Source of wealth and source of funds

“Source of funds” refers to the funds that are being used to fund a specific transaction. It is not enough to confirm which bank account they will come from; you need to understand where the funds ultimately derive from.

You must carry out enquiries to ensure you understand the source of funds for any transaction you are advising on. You must be satisfied that:

• the transaction is being funded via a legitimate source;
• the transaction is consistent with the client and their usual business activities; and
• the source of funds is consistent with the CFOs reasonable assessment.

In certain circumstances, it may also be appropriate to obtain supporting documents to evidence these enquiries.

“Source of wealth” refers to the origin of a client’s entire body of wealth (that is, total assets). It describes the economic, business and commercial activities that generated, or significantly contributed to, the client’s overall net worth or entire body of wealth.

15. Ongoing monitoring

Undertaking effective CDD at the outset of the client relationship significantly reduces the risk of money laundering. However, this is only the first stage of the CDD journey.

CDD is an ongoing obligation that rests with The CFO Centre and each CFO. The purpose of ongoing monitoring is to identify any changes in the client’s risk profile and to detect unusual or suspicious transactions. This requires you to:

• Scrutinise transactions throughout the course of the relationship to ensure that the transactions are consistent with your knowledge of the client, their business and risk profile.
• Stay alert to any changes in the client’s ownership structure and any high-risk factors or suspicious activity that may come to your attention.
• Keep documents, data or information used for the purpose of applying CDD measures up to date.

While ongoing monitoring is the responsibility of each CFO, the Legal and Compliance Team is always available to provide assistance. Any changes to the client’s details or risk profile should be reported by email to the Compliance Officer.

The key changes that should be notified are:

• The appointment of new directors.
• Changes in the ownership structure.
• Any allegations or findings of criminal activity
• Changes in the clients trading activities.
• Transition to a high-risk jurisdiction or market.
• Significant changes in the volume or nature of transactions
• Changes to the client’s regulatory status
• Adoption of unusual payment methods
• Identification of politically exposed persons (PEPs) associated with the client

16. Training

As part of the CFO Centre’s mandatory formal induction, all CFO Centre staff are required to complete an AML and CTF training module and to attest to having read this AML Policy. CFOs are also required to attend the Risk Section of the mandatory induction and read the AML Guidance, which is contained within Schedule 2 of their Contract for Services with the CFO Centre. CFOs are required to periodically attest that they have refreshed themselves as to the Guidance provided by the CFO Centre.

CFOs are reminded that it is a condition their professional membership that they in their own right meet the obligations and responsibilities on them as set out in the AML Legislation.

17. Staff screening

All staff in an AML compliance role or whose work contributes to the identification or mitigation of AML risk are screened before their appointment and at appropriate intervals during their employment. This includes all legal, finance, and client facing employees and contractors.

18. Further assistance

If you are in any doubt about any aspect of this policy or have any queries, please contact the Legal and Compliance Team or speak to the MLRO or Compliance Officer. Please use the contact details set out in Annex A.

Annex A

Key Contact details

Money Laundering Reporting Officer – Nevil Durrant ([email protected])

Compliance Officer – Zoe Wilson, Dip(GRC) ([email protected])

Head of Legal and Compliance – Toby Parkes ([email protected])

Group Risk Advisor – Paul Dodd ([email protected])

Legal and Compliance Team ([email protected])

Annex B

Click to download the Client Due Diligence Checks Annex as a PDF.

Click to download the Risk Assessments Annex as a PDF.

Click to download the Overseas Client Process Annex as a PDF.