Company No: 06913083

Anti-Money Laundering Policy Statement &

Program Procedures 2021(September)

Bayat Traders Ltd has created this policy statement to provide accurate and clear information to its employees
in order to prohibit and actively combat money laundering and terrorist funding through bureau de change
operations. This policy is intended to ensure that all employees follow the requirements and obligations
established by UK legislation for Money Service Businesses.

Registered office address

363, Ballards Lane
North Finchley
London
N12 8L J
United Kingdom

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Contents
Contents ......................................................................................................................................... 2
Glossary of terms ......................................................................................................................... 4
Policy Statement ........................................................................................................................... 8
Introduction .................................................................................................................................. 8
What is ‘‘money laundering’’? ................................................................................................... 9
What is ‘’terrorist financing’’?................................................................................................. 10
What is criminal property? ....................................................................................................... 10
Roles and Responsibilities ......................................................................................................... 11
Director ........................................................................................................................................ 11
MLRO........................................................................................................................................... 12
Compliance officer ....................................................................................................................... 12
STAFF .......................................................................................................................................... 12
The law ........................................................................................................................................ 13
The money laundering legislation in the UK ............................................................................... 13
Proceeds of Crime Act 2002 (POCA) .......................................................................................... 15
Sections 327 to 329: concealing, arranging, acquiring........................................................... 15
Terrorism Act 2000(TA) ............................................................................................................... 17
European Union Fund transfer regulations/Regulation 2015/847/EU........................................ 18
Payment Services regulation 2017 ............................................................................................... 18
UK Bribery ACT 2010 ................................................................................................................. 18
Sanctions and Penalties ............................................................................................................... 18
Sanctions and Anti money laundering Act 2018 .......................................................................... 19
The Money Laundering and Terrorist Financing (amendment) Regulations 2019(MLRs) ......... 20
Terrorist Asset -Freezing etc. Act 2010 ....................................................................................... 20
Anti-Money Laundering Systems and Controls ...................................................................... 21
Risk Based Approach ................................................................................................................ 21
Cash based customer- Risk Assessment ....................................................................................... 21
Online Based Customer- Risk Assessment ................................................................................... 22
Risk Matrix – High, Medium, and Low Risk customers. .............................................................. 22
KYC & KYB ............................................................................................................................... 23
CDD- Customer Due Diligence ................................................................................................... 24
Simplified due diligence ............................................................................................................... 24
identifying individuals .................................................................................................................. 25
Evidence checks for validity ......................................................................................................... 28
Individuals not resident in the UK ............................................................................................... 28
Electronic verification.................................................................................................................. 28
Politically Exposed Persons (PEPs) .......................................................................................... 28

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Customer Behavior ...................................................................................................................... 29
Sanctions List Check.................................................................................................................. 30
Enhanced Due Diligence (EDD) ................................................................................................ 31
How do we apply Enhance due diligence? .................................................................................. 33
Non – compliance with customer due diligence ........................................................................... 33
What is business relationship .................................................................................................... 33
Customer Account ........................................................................................................................ 34
Account opening terms and conditions ........................................................................................ 34
Corporate customers .................................................................................................................... 35
Existing Account Holders Terms and Conditions ........................................................................ 35
Change and modification to client details ................................................................................... 36
Business Monitoring .................................................................................................................... 36
Transaction Processing................................................................................................................ 36
Transaction Monitoring ............................................................................................................... 37
Linked Transactions ..................................................................................................................... 37
Suspicious Activity and Report ................................................................................................. 38
What is suspicious activity (which must be reported)? ................................................................ 38
Suspicion Indicators..................................................................................................................... 38
Suspicious activity report (SAR) – internal company process ..................................................... 39
Making a suspicious activity report (SAR) to NCA ...................................................................... 40
Seeking ‘consent’ ......................................................................................................................... 40
Staff training and awareness ..................................................................................................... 41
Customer complaint procedure ................................................................................................ 42
Procedure..................................................................................................................................... 42
Record Keeping .......................................................................................................................... 43
The record that must be kept ........................................................................................................ 43
How long the customer due diligence records must be kept? ...................................................... 44
In what format must the records be kept? .................................................................................... 44
Privacy & Data Protection ........................................................................................................ 45
What personal data do we collect? .............................................................................................. 45
Appendix A- Threshold Money Transfer ................................................................................ 50
Appendix B- Threshold Bureau De Change ............................................................................ 51
Appendix C- International SAR Format ................................................................................. 52
Appendix D- Large Transaction Declaration .......................................................................... 53

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Glossary of terms

MSB Money Service Business

Money Service Business “Money service business” refers to a company that operates a
currency exchange office, sends money (or any representation of
monetary value) by any means, or cashes checks made payable to
customers as a business.
AML Anti-Money Laundering
Beneficial Owner The person who owns or manages the customer, or on whose
behalf a transaction or activity is being carried out.
Business Relationship According to The Money Laundering and Terrorist Financing
(amendment) Regulations 2019 (MLRs), “business relationship”
means a business, professional or commercial relationship between
a relevant person and a customer, which—
a) arises out of the business of the relevant person, and
b) is expected by the relevant person, at the time when contact
is established, to have an element of duration.

Cash Notes, coins and traveler’s cheques in any currency.

Consent Permission given by the NCA, for the carrying out of any action
that would constitute a money laundering offence in the absence
of that permission.
Criminal Conduct Conduct which constitutes an offence in any part of the United
Kingdom or would constitute an offence in any part of the United
Kingdom if it occurred there.
Criminal Property Any money or other assets which constitutes a person’s benefit
from crime.
Customer due diligence Identifying and verifying the identity of the customer and any
(CDD) beneficial owner of the customer and obtaining information on the
purpose of intended nature of the business relationship.
EEA European Economic Area
Enhanced due diligence Enhanced due diligence applies in situations that are high risk. It
(EDD) means taking additional measures to identify and verify the
customer identity and source of funds and doing additional ongoing
monitoring.
FATF Financial Action Task Force.
Financial Sanctions All individuals and legal entities who are within or undertake
and Target List money service business activities within the UK’s territory must
comply with the EU and UK financial sanctions that are in force.
Most financial sanctions are made through EU law which has direct
effect under UK law.

The Office of Financial Sanctions Implementation works closely with

the EU Commission and other member states in implementing
sanctions. Other financial sanctions are put in place by UK laws.

MSB can report a suspected breach, sign up for free email alerts
and obtain Information on the current consolidated list of asset
freeze targets and persons subject to restrictive measures at:

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 https://www.gov.uk/government/organisations/office-of-financial-
sanctionsimplementation

FCA FCA is a financial regulatory body in the United Kingdom, but

operates independently of the UK government, and is financed by
charging fees to members of the financial services industry. The FCA
regulates financial firms providing services to consumers and
maintains the integrity of the UK’s financial markets. It focuses on
the regulation of conduct by both retail and wholesale financial
services firms.
HMRC Her Majesty’s Revenue and Customs. Supervisory authority for all
MSB.
Identification Ascertaining the name of, and other relevant information about, a
customer or beneficial owner.
Internal SAR Report A report made to the Nominated Officer or MLRO in a
business/MSB while there is any suspicion arises.
JMLSG Joint Money Laundering Steering Group: body representing UK
Trade Associations in the Financial Services Industry and aiming to
promote good anti- money laundering practices and give relevant
practical guidance.
Money Laundering An act which:
• Constitutes an offence under s. 327, 328 or 329 of POCA or
• Constitutes an attempt, conspiracy or indictment to commit
such an offence or
• Constitutes aiding, abetting, counseling or procuring the
commission of such an offence or
• Would constitute an offence specified above if done in the
United Kingdom. [POCA, s. 340 (11)]

A person also commits an offence of money laundering if he enters

into or becomes concerned in an arrangement which facilitates the
retention or control by or on behalf of another person of terrorist
property:
• By concealment
• By removal from the jurisdiction
• By transfer to nominees or
• In any other way.

[Terrorism Act, s. 18]

Money Laundering The Money Laundering and Terrorist Financing (amendment)

Regulations Regulations 2019 (MLRs) (referred to in this guidance as “the
Regulations”)
MLRO MLRO means a “nominated officer”, who is nominated to receive
disclosures under Part 3 (terrorist property) of the Terrorism Act
2000(h) or Part 7 (money laundering) of the Proceeds of Crime Act
2002;
Occasional transaction A transaction (carried out other than as part of a business
relationship) amounting to 15,000 euro or more, whether the

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 transaction is carried out in a single operation or several operations
that appear to be linked.
Ongoing monitoring of a Scrutiny of transactions undertaken throughout the course of the
business relationship relationship (including, where necessary, the source of funds) to
ensure that the transactions are consistent with the relevant
person’s knowledge of the customer, h i s business and risk profile
and Keeping the documents, data or information obtained for the
purpose of applying customer due diligence measures up to date.
OFAC US Treasury Office of Foreign Assets Control. Administers and
enforces economic and trade sanctions based on US foreign policy
and national security goals against targeted foreign countries,
terrorists and international drug traffickers.
POCA Proceeds of Crime Act 2002.
Politically Exposed Person An individual who is or has, at any time in the preceding year, been
(PEP) entrusted with prominent public functions, or an immediate family
member of such an individual, or a known close associate, of such
persons.
Prejudicing an Investigation The making of any disclosure or falsifying, concealing, or destroying,
or being complicit in these, of any documents that are relevant to a
money laundering investigation.
Regulated Sector Persons and firms which are subject to Money Laundering
Regulations.
4th Money Laundering “Fourth money laundering directive” means Directive 2015/849/EU
Directive/ Directive of the European Parliament and of the Council of 20th May 2015 on
2015/849/EU the prevention of the use of the financial system for the purposes of
money laundering or terrorist financing.
Fund transfer “funds transfer regulation” means Regulation 2015/847/EU of the
regulations/Regulation European Parliament and of the Council of 20th May 2015 on
2015/847/EU information accompanying transfers of funds
SAR Suspicious activity report made to NCA.
Internal SAR Suspicious activity reports to the MLRO, by any staff as an internal
reporting procedure within the business.
Senior Management The directors and senior managers (or equivalent), of a firm who are
responsible, either individually or collectively, for management and
supervision of the firm’s business.
Senior Manager “senior management” means an officer or employee of the relevant
person with sufficient knowledge of the relevant person’s money
laundering and terrorist financing risk exposure, and of sufficient
authority, to take decisions affecting its risk exposure.
Simplified due diligence An exception to the obligation to apply the customer due diligence
measures for specified customers, e.g. financial institutions subject
to the Money Laundering Directive or equivalent legislation and
supervision. It is also available for some categories of products and
transactions which may be provided by financial institutions.
NCA National Crime Agency
Supervisory Authority Bodies identified by The Money Laundering and Terrorist Financing
(amendment) Regulations 2019 (MLRs)as being empowered to
supervise the compliance of relevant businesses with the said
Regulations.
Terrorism Act (TA 2000) Terrorism Act 2000, as amended by the Anti-terrorism, Crime and
Security Act 2001.

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Terrorist Financing “Terrorist financing” means (except where the context otherwise
requires) an act which constitutes an offence under—
a) section 15 (fund-raising), 16 (use and possession), 17 (fund-
ing arrangements), 18 (money laundering) or 63 (terrorist fi-
nance: jurisdiction) of the Terrorism Act 2000.
b) paragraph 7(2) or (3) of Schedule 3 (freezing orders: of-
fences) to the Anti-terrorism, Crime and Security Act 2001.
c) regulation 10 (contravention and circumvention of prohibi-
tions) of the ISIL (Da’esh) and Al-Qaida (Asset-Freezing) Reg-
ulations 2011; or
d) section 11 (freezing of funds and economic resources), 12
(making funds or financial services available to designated
person), 13 (making funds or financial services available for
benefit of designated person), 14 (making economic re-
sources available to designated person), 15 (making eco-
nomic resources available for benefit of designated person)
or 18 (circumventing prohibitions etc.) of the Terrorist As-
set-Freezing etc. Act 2010;
Tipping off A tipping-off offence is committed if a person knows or suspects
that a disclosure falling under POCA s 337 or 338 has been made,
and he makes a disclosure which is likely to prejudice any
investigation which may be conducted following the disclosure
under s 337 or s 338. [POCA, s 333A].
Transaction The provision of any advice by a business or individual to a client
by way of business, or the handling of the client’s finances by way
of business. A transaction could be simply operating across a cli-
ent’s account.
Verification Verifying the identity of a customer, by reference to reliable,
independent source documents, data, or information, or of a
beneficial owner through carrying out risk-based and adequate
measures.

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Policy Statement
Bayat Traders Limited is committed to adhering to all applicable money laundering laws and
regulations. Every officer, director, employee, and associated person at Bayat Traders Limited is
responsible for assisting the Firm's efforts to detect, deter, and prevent money laundering and
other activities that facilitate the funding of terrorist or criminal activities.
The current policies are based on information provided by the relevant UK regulatory bodies.
Money Laundering and Terrorist Financing (Amendment) Regulations 2019 – transposing the 5th
AMLD, Anti Money Laundering Guide, Regulation (EU) 2015/847 on information accompanying
funds transfers (the Payments Regulation), and Payment Services Regulations (2017).
I, Tareq Awrangzeb, as director of the company, is committed to operate my business in a
transparent and open manner consistent with the regulatory obligations. As part of this com-
mitment Bayat Traders Ltd ` has adopted strict compliance of all applicable AML rules and
regulations with specific emphasis on POCA (Proceeds of Crime Act 2002), The Money Laun-
dering and Terrorist Financing (amendment) Regulations 2019 (MLRs). (Referred to in this guid-
ance as “the Regulations”) and Payment Services Regulations 2017. Bayat Traders Ltd is aware
that MSBs have in the past been targeted by the organised criminals seeking to launder the
proceeds of illicit activity. Bayat Traders Ltd will always seek to disrupt this activity by coop-
erating fully with the authorities and reporting all suspicious activity to NCA. All staff must take
steps to ensure compliance with this policy and ensure that they fully understand the mate-
rial contained in this policy manual. It is the policy of Bayat Traders Ltd that staff must receive
AML training on commencement of their duties. Staff will be given a copy of this manual and
will be tested on its contents before starting any client facing duties.
The Compliance Manager has reviewed the AML Policy Manual on a yearly basis and/or when a
material change occurs in the Company based on the general principles established by the Com-
pany in relation to the prevention of Money Laundering and Terrorist Financing. The AML Man-
ual may be amended or supplemented as needed for legislative and business operational rea-
sons; however, any change or amendment must be approved by the company.

Introduction
This manual is intended for use by Bayat Traders Ltd employees as a guide to AML and other
security responsibilities for both the company and the staff. It contains information that all em-
ployees must be aware of in order to prevent the business from being used to launder the pro-
ceeds of crime or terrorist financing. All employees are at risk of committing a criminal offence
if they assist in a criminal transaction, either directly or indirectly, by failing to recognise the
warning signs. The risk-based approach is at the heart of this document, which means that we
focus on the areas of greatest risk. The potential for being used to aid in money laundering and
terrorist financing is high for our company.
These risks must be identified, evaluated, and mitigated. We will be better able to assess risks
and detect suspicious activity if we know our customers well and thoroughly understand their
instructions. We will always begin with the assumption that the majority of our customers are
not money launderers or terrorist financiers, but we must assess the risk level specific to our
firm and implement reasonable and deliberate controls to mitigate those risks.
We will be able to justify our position on risk management to law enforcement, courts, HMRC,
and the FCA if we use an effective, risk-based approach and make documented, risk-based judg-
ments on individual and corporate customers.

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What is ‘‘money laundering’’?
Money Laundering is a procedure by which criminal’s money or other assets (criminal property) that
earn illegally are exchanged for ‘clean’ money or other belongings with no obvious hyperlink to
their criminal activities (Drug trafficking, Terrorism, Tax fraud and so forth.) If
undertaken efficaciously it allows them to preserve control over the ones proceeds and in the long
run to have a valid cover for the source of incomes.
cash laundering is the procedure through which criminally acquired belongings may additionally take
any form, including cash or cash’s really worth, securities, tangible belongings, and
intangible belongings. It additionally covers cash, however come by way of, which is used to fund
terrorism.
So very simply money laundering occurs every time any transaction take place, or
any relationship is formed that involves any form of property or benefit that has
come from any crime.
Criminal offence of money laundering is only committed when both the act of
money laundering takes place and the person or business that handles the property
has the required state of mind.

There are three stages or layers to the money laundering process:

Placements: where cash or other type of assets from criminal activities are placed
into a legitimate financial system.

Layering: usually involves a series of transactions designed to hide the source

and ownership of the funds and confuse the authorities and financial system.
Bye moving the money around and create a complex transaction to hide the
main source of found ‘’crime’’ like wiring and transferring through numerous
accounts.

Integration: where criminal found reintroduced into the legitimate economy

showing it come from clean and legitimate source.
Some of these steps may be omitted, depending upon the circumstances. For
example, non-cash proceeds that are already in the financial system would not
need to be placed or it is integrated into the financial system through additional
transactions until the "dirty money" appears "clean”.
Money laundering does not always occur in a manner that fits into the three sages.

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What is ‘’terrorist financing’’?
Traditionally, AML efforts have focused on identifying the proceeds of various types of criminal
activity. Terrorist financing is a sort of criminal behavior that involves money and poses a major
threat to financial institutions. Terrorist funding is frequently compared to money laundering to
highlight some of the similarities, as well as some major differences. The similarities and differ-
ences are frequently classified based on the source of finances, the destination of the founds,
and the goal of the activity.

Source
with money laundering, there has to have been an original crime which generated the money –
e.g. drug deal, tax evasion, human trafficking, a bribe or a fraud etc. with terrorist financing,
although illegally earned money is often used, it does not have to be the case, the source of the
founds may be legitimate- I may wish to send my legally earned money from my salary to a
terrorist organization; the money was legitimate earned but it is the funding that illegal.

Destination of the funds

with money laundering, the money generated from the illegal activities serves to profit the peo-
ple involved in the activity itself. In the sense, ML is often said to be circular although this is
slightly misleading as the funds also end up with perfectly legitimate recipients who may have
no idea of the illegal origin of the funds for example if I buy a car with my drug money. With
terrorist financing, the recipient is, by definition, a terrorist or a terrorist organisation. In this
sense, TF is said to be Linear example it is send by one person (who is not necessarily involve in
terrorism) to a terrorist or terrorist organization.
Purpose of the activity
In general, criminals will use their illegally earned money to fund more illegal activities. The pri-
mary goal is to make money. Again, the main purpose of terrorist financing, by definition, is to
support terrorists and terrorist organisations by funding their activities, purchasing weapons,
and so on.

What is criminal property?

Criminal property is the proceeds of criminal conduct, this includes any type of conduct, wher-
ever it takes place, which would constitute a criminal offence if committed in the UK. Many
crimes generate property that can be laundered, but the criminal offence of money laundering
generally only occurs when a person handles property that has been generated by certain types
of crime. It includes drug trafficking, terrorist activity, tax evasion, corruption, fraud, forgery,
theft, counterfeiting, blackmail, and extortion. It also includes any other offence that is commit-
ted for profit.
The issue becomes complex when several countries are involved in process.
For example, the definition of criminal conduct in the UK was amended by the serious organized
crime and police Act 2005 (SOCPA). SOCPA introduced a new offence to the primary money laun-
dering offences and the failure to report offences, where the underlying criminal conduct gen-
erating the criminal property took place overseas and was lawful there.

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Roles and Responsibilities
Director
It is a position of responsibilities and trust, as a result there are number of duties as well as legal and
financial responsibilities which must be aware of it. There will be legal consequences if operate outside
these rules and regulation. According to companies Act 2006 there are seven general duties that apply
to director that they are personally subjected to statutory duties. As a legal entity the company is
subjected to UK and EU legislation with regards to how the business operates, these are known as
statutory controls, and the director is responsible for ensuring that the company complies with these
statutory.
Some of the responsibilities.
• Financial and legal responsibilities
• Submitting the company records on time
• Submitting of annual return and annual accounts to company house
• Corporation tax return to HM revenue and customs with electronic payment for any taxes the
company owe
• Inform the Company House of any changes, personnel, company’s registered office and any
shareholders allocation.
• Meet all tax obligation, ensure all taxes, national insurance contributions to HM Revenue and
customs on time for both director an employee.
• Maintain accurate company records.
• Direct and control finance staff to ensure that they are appropriately motivated and devel-
oped and so that they carry out their responsibilities to the required standard.
• Contribute to the achievement of the company's business objectives by providing advice and
guidance on financial strategy.
• Develop and control the company’s annual operating budget to ensure that all financial tar-
gets are met, and financial and statutory regulations complied with.
• Provide financial advice and guidance to the company's managers and staff to enable them to
achieve their objectives.
• Oversee the preparation of the company's financial accounts to ensure that these are pre-
sented accurately and on time.
• Develop and implement an internal audit programme to ensure that the company complies
with financial procedures and regulations.
• Develop and maintain all necessary systems, policies, and procedures to ensure effective and
efficient financial management within the company.
• Monitor external contracts and services provided by suppliers to ensure that these are oper-
ating effectively and provide the best value to the company.
• Carry out all necessary actions to ensure that the company meets its financial and legal obli-
gations.

MLRO
The MLRO role is to be aware of any suspicious activity in the business that might be link to money
laundering and terrorist financing. The MLRO is responsible for receiving internal reports and
making reports to NCA if there is any suspicious activity is identified. The first point of contact for
all compliance issues from staff is MLRO. He prepares an annual report for consideration and
conducts risk assessments of compliance systems. MLRO undertakes the regular random analysis
of transactions including assessment of documentary evidence provided by customers. The MLRO
also responsible for the following points too.

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 • Implementing and maintaining anti-money laundering
controls and procedures
• Conducting money laundering risk assessments
• Records Keeping
• Training staff in preventing money laundering

Deputy Compliance officer

The compliance officer is responsible for the compliance with the regulations including:
• Carrying out regular audit on compliance with the regulations such as:
- actively check adherence to the policies, controls, and procedures
- review of how effective they are
- recommend and carry out improvements
• ensure compliance throughout the business including subsidiaries and branches if there is any.
• oversight of relevant staff and other MSB screening if there is any.
• Perform risk assessments to understand risk level
• Keep up to date with, and understand relevant laws and regulations
• Monitor compliance with laws, regulations internal policies
• Ensure that your findings are recorded and followed up with management so that issue can
be certified
• Educate employees on regulation and impact on organisations if these aren’t complied with
highlight and escalate areas of concern
• Contribute to robust and effective compliance and effective compliance controls within the
organisation
• Assist in the gathering of internal information in response to regulatory request

STAFF
All employees are responsible for reading the AML manual, understanding their responsibilities, and
acting appropriately. Ensure that company procedures are followed and that all documentary
evidence is obtained as specified in the manual. Ensure that all suspicious events are reported to
MLRO.

The law
The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (MLRs) require the
firm to give money laundering/counter-terrorism financing training to all employees. In accordance
with that duty, we have included a summary of the legislation and the major problems that all staff
members must be aware of below. The relevant law is outlined in full below. We make certain that all
our employees have studied the legislation and are aware of the potential criminal offences and fines.
To minimise misunderstanding, HMRC guidance on the legislation is given when applicable.

The money laundering legislation in the UK

The legislation governing money laundering and Terrorist Financing and the fight
against it is contained in the following primary legislation:
Proceeds of Crime Act 2002 https://www.legislation.gov.uk/ukpga/2002/29/part/7
part 7 ss.327 – 340
Terrorism Act 2000 https://www.legislation.gov.uk/ukpga/2000/11/part/III
Criminal Finances Act 2017 https://www.legislation.gov.uk/ukpga/2017/22/part/1/chap-
ter/2

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The Bribery Act 2010
Note: more details regarding
Bribery and Corruption are
contained in the Manuals
https://www.legislation.gov.uk/ukpga/2010/23/contents
Bribery and corruption often involve “ill-gotten gains” giving
rise to the need to launder the proceeds and also a business
that deals in millions of pounds of cash are vulnerable to be-
ing targeted by
those who wish to bribe or corrupt

Terrorist Asset-Freezing etc. https://www.legislation.gov.uk/ukpga/2010/38/part/2

Act 2010

Anti-terrorism, Crime https://www.legislation.gov.uk/ukpga/2001/24/contents

and
Security Act 2001

Counter-Terrorism Act 2008, https://www.legislation.gov.uk/ukpga/2008/28/schedule/7

Schedule 7

The Regulatory Framework is shown below; it outlines the obligations for businesses and
individuals in response to primary laws. This statement's goal in terms of money
transmission is to put these Regulations into effect.

Regulation (EU) 2015/847 on information ac- https://eur-lex.europa.eu/legal- con-

companying transfers of funds (the Payments tent/EN/TXT/PDF/?uri=CELEX:32015R084 7
Regulation)
Payment Service Regulations 2017 https://www.legislation.gov.uk/uksi/2017/75
2/contents
Money Laundering, Terrorist Financing and https://www.legislation.gov.uk/uksi/2017/69
Transfer of Funds (Information on the Payer) 2/contents
Regulations
2017 – hereafter referred to as the “2017
Regs”.
Money Laundering and Terrorist Fi- https://www.legislation.gov.uk/uksi/2019/15
nancing Regulations [Amendments] 2019 11/contents/made
“The 2019 Regs”
For more reading the following websites contain the details of different issues discussed in these
documents:

Financial https://www.fca.org.uk/firms/financial-crime/money-laundering-
terrorist-financing
Conduct
Authority (FCA)
website;

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HM Revenue & www.hmrc.gov.uk
Customs (HMRC) fit and proper
https://www.gov.uk/government/publications/money-laundering-
supervision-fit-and-proper-test-and-approval/money-laundering-
supervision-guidance-on-the-fit-and-proper-test-and-hmrc-ap-
proval penalties
https://www.gov.uk/government/publications/money-laundering-
supervision-enforcement-measures/money-laundering-supervi-
sion- civil-measures
MSB Anti ML Supervision [link below]
Office of Foreign www.treasury.gov/ofac
Assets Control
(OFAC);
HM Treasury www.hm-treasury.gov.uk
we should consider the following and, in any event, these will be discussed during training programs:
• HMT National Risk Assessment
https://www.gov.uk/government/publications/national-risk-assessment-of-
money-laundering-and-terrorist-financing-2017

• HMRC – understanding risks and taking action for money service Business

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachme
nt_ data/file/945411/NRA_2020_v1.2_FOR_PUBLICATION.pdf

• HMRC “Anti-Money Laundering Supervision: Money Service businesses

This Guidance has been approved by HM Treasury. It will be known as the "HMT Guidance."
Every member of SM, as well as other "relevant employees," is expected to read this
Guidance in addition to the AML Response. The guideline describes the provisions outlined
in the 2017 REGS, as well as the 2019 changes to those Regulations.

https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachmen
t_ data/file/889077/UTF-8 Guidance-for-Money-Service-Businesses-HM-Treasury-
approved.docx_.pdf
This is the link to the document.

“Relevant staff” is defined as persons involved in the identification of risk, controls, and procedures
to reduce risk and to ensure Company compliance with the Regulations.

Proceeds of Crime Act 2002 (POCA)

POCA, as amended, establishes a number of money laundering offences including:

• principal money laundering offences.
• offences of failing to report suspected money laundering.
• offences of tipping off about a money laundering disclosure.
• tipping off about a money laundering investigation; and
• prejudicing money laundering investigations.

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POCA applies to all members of Bayat Traders Ltd’s staff as our business is in the regulated sector and
so all the offences outlined above are applicable to you.
Sections 327 to 329: concealing, arranging, acquiring
These offences apply to all staff.

Section 327 it is an offence to conceal, disguise, convert, transfer or remove (from the UK)
criminal property.
Section 328 it is an offence to become concerned in an arrangement which a person knows,
or suspects facilitates the acquisition, retention, use or control of criminal
property
Section 329 it is an offence to acquire, use or have possession of criminal property

These are the ‘main’ money laundering offences and where we refer to ‘Money Laundering’ in this
section, what is mean is the attempt, conspiracy to or commission of these offences.
"Criminal property" is property which:
• is or represents a person's benefit from criminal conduct; and
• the alleged offender knows, or suspects constitutes or represents such a benefit
"Criminal conduct" is conducting which:
• is an offence in any part of the UK; or
• is an offence in the jurisdiction where the conduct took place
• or where the conduct took place outside the jurisdiction, but would have if it occurred in the
UK, attracted a maximum penalty of over 12 months imprisonment
These offences apply to the proceeds of all crimes and to any type of criminal conduct, regardless of
amount.

Penalty
These offences are punishable upon conviction by a maximum of 14 years imprisonment.

The defenses
• You did not know or suspect that the money or property in question was ‘criminal property’.
Deliberately shutting your eyes to an obviously suspect situation will not constitute a defense.
• We made an authorised disclosure i.e.:
- a disclosure to a nominated officer (i.e. using the firm’s internal reporting procedure to
MLRO); and
- made in the form and manner prescribed in the regulations;
Authorised disclosures: It can be made either before or after a "prohibited act" occurs, i.e. before the
completion of any transaction which amounts to a money laundering offence. External disclosures,
by the MLRO, are made to the National Crime Agency (“NCA”).
Pre-transaction disclosures: Where a suspicion has arisen before a "prohibited act" occurs, it will be
necessary to receive the appropriate consent before completing any transaction which would amount
to a prohibited act. If the prohibited act takes place without this consent, then the disclosure defense
will not apply.
Appropriate consent must be given by the person who received the authorised disclosure, in this case
the MLRO. However, the MLRO cannot give consent until a report has been made to the NCA and
NCA has given actual or presumed consent (see below). It is an offence for the MLRO to give
consent when they should not have done the above.
Time limits for disclosure: section 335 lays down time limits relating to the delay between the
authorized disclosures being made and the appropriate consent being given or presumed.
• If the person making the disclosure either receives appropriate consent or hears nothing
within seven working days, the transaction can proceed, and the disclosure defense will be

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 available. The seven-day period is known as the "notice period";
• If consent is refused within the notice period, the transaction cannot safely proceed unless
consent has been given within the "moratorium period" or the "moratorium period" has ex-
pired. The moratorium period starts when the appropriate consent is refused and lasts
31 days
Post transaction disclosure is a disclosure which is made after the "prohibited act” has occurred. In
this case appropriate consent will not be required but the disclosure defence will only apply if a
person had a reasonable excuse not to report beforehand.
Adequate consideration defence -- there is a defence to section 329, that a person has been paid a
proper amount for providing goods and services. However, this defence does not apply if the
person knew or suspected that the goods or services they were providing, and being paid for,
might help another to carry out criminal conduct.

Sections 330 failure to disclose: regulated sector

The s330 offence in the Act has been amended by NCA in a number of key respects:
The offence applies when a person:
• knows or suspects, or
• has reasonable grounds for knowing or suspecting that another person is engaged in money
laundering.
• can identify the money launderer or the whereabouts of the laundered property
• or that he believes that the information he has may assist in identifying the other person or
the whereabouts of any of the laundered property
The disclosure must be made as soon as is practicable and must have been made during business. The
disclosure must be made to the MLRO or to NCA.
This offence introduces an objective test for knowledge or suspicion. This means that a person may
be guilty of this offence if there were reasonable grounds for knowledge or suspicion i.e., they
should have known or suspected.
Penalty - Punishable on conviction by a maximum of five years imprisonment.
Defences to failure to disclose regulated sector
• Employees in the regulated sector who have not received training about money laundering
from their employer may have a defence. However, this defence is only available if the
employee did not have actual knowledge or suspicion. In these circumstances there would
be ramifications for the employer.
• It could also be a defence if the person has a "reasonable excuse" for not disclosing the
information.

Section 333A (1) and (3) tipping off

• S333A (1) – disclosing a suspicious activity report (SAR). It is an offence for a person to make
a disclosure which is likely to prejudice an investigation when the person knows or suspects
that an authorised disclosure has been made.
• S333A (3) – disclosing an investigation.
It is an offence to disclose that an investigation into a money laundering offence is being
contemplated or carried out if that disclosure is likely to prejudice that investigation. The
key point is that you can commit this offence, even where you are unaware that a SAR was
submitted.
Disclosure- The disclosure in this context means any form of communication to anyone, not just our
own customer.
The defenses
It is a defence if the person did not know or suspect that the disclosure was likely to prejudice an
investigation.

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 • S333B – Disclosures within an undertaking or group etc.
It is not an offence if an employee of a firm discloses that a SAR has been made if it is to
an employee of the same business.
Any concerns about tipping off should be referred to the MLRO.

Terrorism Act 2000(TA)

The TA, as amended, establishes several offences about engaging in or facilitating terrorism, as well
as raising or possessing funds for terrorist purposes. It establishes a list of organizations the
Government believes are involved in terrorism. The Terrorism Act applies to all persons. There is a
failure to disclose offence and tipping off offences for those operating within the regulated sector.
Section 18 – money laundering
It is an offence to enter or become concerned in an arrangement facilitating the retention or control
of terrorist property by, or on behalf of, another person including, but not limited to the following
ways:
• By concealment
• By removal from the jurisdiction by transfer to nominees
It is a defence if you did not know, and had no reasonable cause to suspect, that the arrangement
related to terrorist property.
Section 21A- tipping off
It is a criminal offence for those in the regulated sector who fail to make a disclosure to either a
constable or the firm's nominated officer where t h e r e are reasonable grounds for suspecting that
another person has committed an offence.
Section 21D (1) and (3) tipping off offences
• Section 21D (1) – disclosing a suspicious activity report (SAR).
It is an offence to disclose to a third person that a SAR has been made by any person
to the police, HM Revenue and Customs, NCA or a nominated officer, if that disclosure might
prejudice any investigation that might be carried out as a result of the SAR.
• Section 21D (3) – disclosing an investigation.
It is an offence to disclose that an investigation into allegations relating to terrorist property
offences is being contemplated or carried out if that disclosure is likely to prejudice that
investigation.
• Section 21E– Disclosures within an undertaking or group etc
It is not an offence if an employee of a firm discloses that a SAR has been made if it is to an
employee of the same business.
Any concerns regarding tipping off should be referred to the MLRO.

European Union Fund transfer regulations/Regulation 2015/847/EU

This regulation applies to our business as we transfer money on behalf of clients. Its basic aim is
to ensure that complete information on the person sending money (payer) is sent with the transfer
to the beneficiary (payee). It is to enable law enforcement to detect and trace the assets of
criminals or terrorists. We must also identify and verify customers who transfer money, irrespective
of the amount. For payments within the EU we need only send a name and account number.

Payment Services regulation 2017

The regime originates from a European Community law – the original Payment Services Directive (PSD)
was introduced in 2007 and became UK law in 2009 through the Payment Services Regulations (PSRs).

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The aim of the PSD is to foster a single market in retail payment services across the European Economic
Area by removing barriers to entry and ensuring fair market access to enhance competition in payment
services; and establishing the same set of rules across the EEA on information requirements and other
rights and obligations that will be applicable to many payment services transactions in the EEA.
Now, revised Payment Services Directive (PSD 2) is in effect, which was published in the European
Union’s official Journal on 23 December 2015. HM Treasury has transposed PSD2 into UK legislation
in the Payment Services Regulations 2017 (PSRs 2017) which has replaced the Payment Services
Regulations 2009. FCA is the competent authority responsible for authorizing and supervising
payment service providers under PSD2.
PSD2 aims to:
• contribute to a more integrated and efficient European payments market
• improve the level playing field for payment service providers
• promote the development and use of innovative online and mobile payments
• make payments safer and more secure
• protect consumers
• encourage lower prices for payments
UK Bribery ACT 2010

The Bribery Act 2010 came into force on 1 July 2011. It amends and reforms the UK criminal law and
provide a modern legal framework to combat bribery in the UK and internationally.
The Bribery Act creates the following offences:
• Active bribery: promising or giving a financial or other advantage
• Passive bribery: agreeing to receive or accepting a financial or other advantage
• Bribery of foreign public officials
• The failure of commercial organisations to prevent bribery by an associated person
Under the current law imprisonment for up to seven years with unlimited fine will increase under the
Bribery Act to a maximum of 10 years imprisonment.

Sanctions and Penalties

If a person or business fails to comply with the ML Regulations, they may face a civil
financial penalty or criminal prosecution that could result in an unlimited fine and/or a
prison term of up to 2 years.
The office of Financial Sanctions implementations, a part of HM Treasury, maintains a list of
sanctioned individuals and countries with whom any financial dealing is restricted. It is a criminal
offence to make payments or allow payments to be made to these targets. The Office of Financial
Sanctions Implementation works closely with the EU Commission and other member states in
implementing sanctions. Other financial sanctions are put in place by UK laws.

In general terms, any person to whom the relevant Statutory Instrument applies who, except under
the authority of a licence granted by HM Treasury under the relevant Statutory Instrument, makes
any funds, economic resources or, in some circumstances, financial (or related) services available
directly or indirectly to or for the benefit of persons listed under the relevant Statutory Instrument
or EC Regulation is guilty of an offence.
The MLRO/Compliance Officer undertakes regular client screening against the relevant databases
including whenever an update is issued by the office of Financial Sanctions. All customers’ and
beneficiaries’ names are checked against international lists of sanctioned targets.
If a similar matching result is found, we do the following:
• Apply EDD and add customer to our internal watch list to carry out ongoing monitoring.

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If an exact matching result is found, we do the following:
Make a disclosure to the relevant authority (NCA) and block the customer in our operational system
until consent is given to proceed or refuse. In addition, we may cease the business relationship with
the customer allowing 30 days’ notice to comply with out Terms & Conditions
HMRC also has the power to:
● suspend or cancel a business’ registration
● ban or suspend individuals from having a role in a supervised business
● issue a statement censuring the business.

HMRC usually publishes details of penalties and sanctions issued. For more information on
the penalties please see https://www.gov.uk/guidance/money-laundering-regulations-
appeals-and-penalties

Not complying with the Regulations may also lead to money laundering charges under the
Proceeds of Crime Act 2002.

Sanctions and Anti money laundering Act 2018

The Sanctions and Anti-Money Laundering Act 2018 (SAMLA) provides the power for the
UK to impose sanctions where appropriate for compliance with United Nations obligations
or other international obligations as well as for several other specific purposes, including
furthering the prevention of terrorism in the UK or elsewhere and protection of UK national
security interests. SAMLA enables sanctions to continue uninterrupted at the end of the
EU exit transition period. Secondary legislation under SAMLA, in the form of Statutory
Instruments, transfer existing EU sanctions into UK law.

SAMLA also enables the UK to bring into force autonomous sanctions regimes. On 6 July
2020, the Global Human Rights (GHR) sanctions regime was established via The Global
Human Rights Sanctions Regulations 2020 under SAMLA. The GHR sanctions regime allows
the UK government to impose sanctions in response to certain serious human rights
violations or abuses around the world. The regime is intended to target individuals or
organisations involved in serious human rights violations or abuses. The measures which
can be imposed under the GHR sanctions regime are travel bans and asset freezes.

Overall, SAMLA provides the power for the UK to impose a range of sanctions, including
trade sanctions such as arms embargoes, immigration sanctions such as travel bans, and
financial sanctions such as asset freezes.

The Money Laundering and Terrorist Financing (amendment)

Regulations 2019 (MLRs)

The Money Laundering and Terrorist Financing (amendment) Regulations 2019 (MLRs) has repealed
and replaced The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the
Payer) Regulations 2017. The Money Laundering and Terrorist Financing (amendment) Regulations
2019 (MLRs) come into force on 10 January 2020. They set requirements for the anti-money
laundering regime within businesses and outline the scope of customer due diligence. The regulations

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aim to limit the use of MSB for money laundering by requiring businesses to know their clients and
monitor the use of their services by clients.
Every person who carries on relevant business in the United Kingdom must –
• establish and maintain policies, controls, and procedures to mitigate and manage effectively
the risks of money laundering and terrorist financing identified in any risk assessment under-
taken by the relevant person.
• regularly review and update the policies, controls and procedures established.
• maintain a record in writing of—
- the policies, controls and procedures established.
- any changes to those policies, controls and procedures made as a result of the review
and updated; and
- the steps taken to communicate those policies, controls and procedures, or any
changes to them, within the relevant person’s business.

Terrorist Asset -Freezing etc. Act 2010

The UK terrorist asset freezing regime meets obligations placed on the UK by UN Security
Council Resolutions (UNSCRs) and associated EU regulations. It is implemented by the
Terrorist Asset-Freezing etc. Act 2010 (TAFA).

TAFA is currently the UK’s main domestic counter-terror asset-freezing legislation, with HM
Treasury responsible for final designations. Between 1 April 2019 and 31 March 2020, HM
Treasury renewed the designations of 18 individuals and entities. HM Treasury delisted
one entity (Hizballah Military Wing) under TAFA but also added one entity (Hizballah). This
decision aligns with the UK decision made in 2019 to proscribe the entire Hizballah
organisation under the Terrorism Act 2000.

The Counterterrorism (Sanctions) (EU Exit) Regulations 2019 under SAMLA are designed to
replace TAFA with substantially the same effect. Using the powers in SAMLA, this new
regulation will enable the domestic counter-terrorist sanctions regime to operate more
effectively and will ensure that elements of the counter-terrorism sanctions regimes are
harmonised with other sanctions regimes. These regulations will come into force from the
end of the EU Exit transition period.

Anti-Money Laundering Systems and Controls

Under The Money Laundering and Terrorist Financing (amendment) Regulations 2019 (MLRs), we are
required to establish appropriate risk-sensitive policies and procedures in order to prevent activities
related to money laundering and terrorist financing.
Our money laundering system and controls provide for:

• Identification and scrutiny of complex or unusually large transactions, unusual patterns of

transactions with no apparent economic or lawful purpose and other activities regarded by
the regulated person as likely to be of the nature of money laundering or terrorist financing.
• Prevention of the use of products favouring anonymity.
• Determination of whether a client is a PEP, using the system’s screening procedure. The sys-
tem also matches all customers’ and beneficiaries’ names against PEP databases worldwide.
• Customer due diligence i.e., procedures designed to acquire knowledge about our customers
and to verify their identity, as well as monitor business relationships before executing the re-
mittances.

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 • Internal reporting, including the appointment of an MLRO to receive the money laundering
reports required under POCA and the TA 2000 and a system for making those reports.
• Record keeping, including details of customer due diligence and supporting evidence for busi-
ness relationships, which need to be kept for five years after the end of a relationship.
• Internal control, risk assessment and management, compliance monitoring, and
• Measures to make employees aware of the law relating to money laundering and terrorist
financing, and to train our employees to recognise and identify and deal with transactions
which may be related to money laundering or terrorist financing.

Risk Based Approach

Cash based customer- Risk Assessment
• Our risk-based approach allows us to target resources and effort where the risk is greatest
and, conversely, reduce requirements- where the risk is low.
• We have established adequate and appropriate policies and procedures relating to risk as-
sessment and management in order to prevent operations related to money laundering, ter-
rorist financing and fraud. We have done this by preparing a risk matrix to be adopted by all
staff.
• We have:
a) determined the extent of customer due diligence measures on a risk-sensitive basis
depending on the type of client, business relationship, or services to be provided.
b) been able to demonstrate to HMRC and FCA that the extent of customer due dili-
gence measures is appropriate in view of the risks of money laundering and terrorist
financing. Our CDD measures are set out in this manual below.
• Our risk-based approach has adequate measures to verify the identity of beneficial owners,
so we know who the beneficial owner of our customer is and what the control structure of a
corporate client is (although we don’t have any corporate customer yet). Every personal cus-
tomer is asked about any beneficial owners on our compliance form. Corporate customers
undergo thorough beneficial ownership assessment in line with our obligations under the Reg-
ulations.
• We scrutinize transactions and other activities throughout the course of any business rela-
tionship to ensure consistency with our knowledge of our customers, their business and risk
profile. The MLRO/Compliance Officer conducts ongoing monitoring of all high-risk accounts
including customers who regularly transfer every month. In addition to this the MLRO/Com-
pliance Officer undertakes random monthly checks upon customer accounts and produce a
report of his findings.
• We also keep up to date information in applying CDD (customer due diligence) measures. All
ID will be retaken on the expiry of any documents used to verify customers. Customer ac-
counts will be placed on hold until the relevant CDD checks have been undertaken or docu-
ments provided.
• We are applying CDD measures at appropriate times to existing clients on a risk- sensitive
basis. The compliance officer assesses the existing CDD database to identify those customers
that may require further/updated CDD checks.

Online Based Customer- Risk Assessment

As we have discussed earlier that most of our operations are cash based and we have limited online
customer activity. But we have plans to expand our business towards online payment operation in the
future. We have given below our risk assessment procedure for our prospective online customers.

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 • We are applying CDD measures at appropriate times to existing clients on a risk- sensitive
basis. The compliance officer assesses the existing CDD database to identify those customers
that may require further/updated CDD checks.
• We have established adequate and appropriate policies and procedures relating to risk as-
sessment and management in order to prevent operations related to money laundering, ter-
rorist financing and fraud.
• These checks are initiated when the customer attempts to pay for their transaction via Card.
After the customer enters their card details, a new window appears, requesting a personal
security code. The customer’s financial institution authenticates the transaction, as well as
confirm the details of the individual making the purchase. Additionally, the address submitted
by the customer is checked against the billing address of the card – the card will only be pro-
cessed if the two matches.
• Due to most of our transactions being processed on the next two to three business days, there
is often enough time to perform a daily check on all transactions which have been paid for by
debit card. Analysts review these transactions looking for suspicious patterns (multiple at-
tempts with same card/multiple attempts with multiple cards/etc.) to identify potential fraud.
If fraud is identified in time, the transaction is refunded to the sender, or we may consider
reporting the issue as major incident to the FCA as well as NCA.
• Certain rules have been developed in our system to automatically suspend transactions that
are deemed at risk for fraud. While each suspension doesn’t necessarily mean that it’s fraud-
ulent – it is highlighted for review by an analyst who may request additional information from
the sender to better confirm their identity. Automated rules are periodically reviewed and
changed due to the changing nature of the fraud risk.
• Accounts that have been suspected or that are known to have received proceeds of fraud are
added to an internal blacklist maintained by Bayat Traders Ltd’s AML Compliance team. Ac-
counts in this internal blacklist cannot receive transactions – those transactions are always
refunded back to the sender.
Risk Matrix – High, Medium, and Low Risk customers.
It is the responsibility of the Money Laundering Reporting Officer (MLRO) to oversee all
transactions, which are processed. They focus attention on high-risk transactions
(transactions with a risk rating of High).

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 Summary of red flags Action of
MLRO
Freeze transaction and report
Sanctions list match
to NCA/HM Treasury
The customer previously reported to NCA and NCA Freeze transaction and report
withheld consent to NCA
Freeze transaction pend-
The customer provides a fake ID
ing enhanced due dili-
gence check
The customer previously reported to NCA and consent
EDD required
given
The transaction is processed non-face to face (and cus-
EDD required
tomer
not previously identified)
Single cash transaction above 2500 Euros (or local equiv-
EDD required
alent)
where no source of funds established
A retail customer has sent cash transactions above 7500
Euros (or local equivalent) within 12 month period (and
no source of funds established) EDD required
The customer is a PEP
EDD required
The customer uses an unusual ID to identify himself
EDD required
Customer is processing level of transactions incompati-
EDD required
ble
with work status
The customer is demonstrating unusual behaviour
EDD required
(which may be suspicious)
The customer is an MSB who is transacting outside antic-
ipated parameters set at the start of the business
relationship EDD required
The customer is an MSB and ownership is not clear/MSB
EDD required
not able to verify ownership

KYC & KYB

KYC & KYB requirement are key aspects in Bayat Traders Limited relationships with its clients.
KYC also known as (customer due diligence). KYC & KYB checks effectively enable Bayat Traders to
verify the identity of a client or customer, to do this Bayat Traders will obtain crucial details about the
individuals and Businesses. When it comes to KYC checks, Bayat Traders identify individuals, so it will
be needed to access to details like their full name, date of birth, and address. On another hand KYB
checks verify the existence of a business, and to do this Bayat Traders will confirm that the firm is
registered with Company House, and identify anyone who with significant control, ultimate beneficial
owners. It may also need to be examine the company’s annual returns and statements in some

Page 23 of 53
situations.
The requirement to carry out customer due diligence and enhance due diligence has given it an
increased importance.

CDD- Customer Due Diligence

This section sets out the standard identification requirements for our customers who are private
individuals. This is likely to be sufficient for most situations. If, however, the customer or transaction
is assessed as presenting a higher money laundering or terrorist financing risk, in line with our
identified risk matrix, then we require additional identity information to be provided and increase the
level or verification accordingly.
Where the result of the standard verification check gives rise to concern or uncertainty over
identity, the number of matches that will be required to be reasonably satisfied as to the individual’s
identity will increase. Any concerns must be notified to the MLRO.
Staff may also need to follow this guidance when identifying and verifying the identity of beneficial
owners and any other relevant individuals associated with the relationship or the transaction. Any
issues relating to beneficial owners should be raised with the MLRO.
All documentary evidence must be dated within the past 3 months and the date of expiry noted
on the system. Staff will be prompted by the system when any ID is due to expire and will need
to request a new identification document from customers before the transaction may continue
or account operate.

Simplified due diligence

Bayat Traders Limited may apply a simplified form of due diligence in some cases. While
risk assessing the customer to establish that they are low risk.
This does not mean we do not have to perform customer due diligence, we still required
to verify customer and beneficial owner identity:
• verifying the customer or beneficial owners’ identity:
o during the establishment of a business relationship or
o use one document to verify identity
o use information you must determine the nature or purpose of a business rela-
tionship without requiring further information, for example, if your customer
is a pension scheme you can assume what the purpose is

To apply simplified due diligence, we ensure that:

• decision is supported by your customer risk assessment
• enhanced due diligence does not apply
• while monitoring the business relationship or transactions we ensure that
there is nothing unusual or suspicious
• it is not prevented by information on risk provided by HMRC or any other authority
• the customer is not from a high risk third country identified by the EU
• the customer is not a politically exposed person, a family member, or a known
close associate of a politically exposed person
• the customer is seen face to face as is any co-owner
• the source of funds or wealth are transparent and understood by our business
• the transaction is not complex or unusually large, that is, over £1 million alt-
hough your risk assessment may indicate that a lower sum would be considered

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 large in your geographical location
• where the customer is not an individual, that there is no beneficial ownership
beyond that legal entity.

To decide whether a customer is suitable for simplified due diligence we consider

among other factors the type of customer, the underlying product or service and the
geographical factors, in our risk assessment. One factor, on its own, should not be
taken to indicate low risk.
Type of customer that may indicate lower risk:
• a public authority or publicly owned body in the UK
• a financial institution that is itself subject to anti-money laundering supervision
or equivalent regulation in another country
• a listed company that is subject to disclosure provisions
• beneficial owners of pooled accounts held by a notary or independent legal pro-
fessional, provided information on the identity of the beneficial owners is avail-
able upon request
• the customer is a European Community institution

Geographical factors that may indicate a lower risk are where the customer is:
• resident or established in another EU state
• situated outside the EU in a country:
o subject to equivalent anti-money laundering measures
o with a low level of corruption or terrorism
o has been assessed by organisations such as Financial Action Task Force (FATF)
and the World Bank as having in place effective anti- money laundering
measures

We consider all the factors, for example a customer from another EU state is not
automatically low risk simply because they are from the EU. All the information we
have on a customer must indicate a lower risk.
We record evidence, as part of your risk assessment, that a customer or service
provided is eligible for simplified due diligence. We conduct ongoing monitoring in
line with your risk assessment to ensure that the circumstances on which we based
our original assessment have not changed.
We discontinue with simplified due diligence if we:
• suspect money laundering or terrorist financing
• doubt whether documents obtained for identification are genuine
• circumstances change and your risk assessment no longer considers the cus-
tomer, transactions, or location as low risk

identifying individuals
Bayat Traders verify its customers by using current government issued documents
with the customer’s full name and photo, with a customer’s date of birth or
residential address such as followings
• A valid passport
• A valid photo card driving license (full or provisional)
• A national identity cards
• An identity card issued by the Electoral Office for Northern Ireland

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When verifying the identity of a customer using the above list of government issued documents we
take a copy and keep it in the customer’s file.
Where the customer doesn’t have one of the above documents we ask for the following:-
A government issued document (without a photo) which includes the customer’s full name
and also secondary evidence of the customer’s address, for example an old style driving
licence or recent evidence of entitlement to state or local authority funded benefit such as
housing benefit, council tax benefit, pension, tax credit.
Secondary evidence of the customer’s address, not downloaded from the internet, for
example a utility bill, bank, building society or credit union statement or a most recent
mortgage statement.
If Bayat Traders Limited verify the customer’s identity by documents, Bayat Traders Limited
see the originals and not accept photocopies, nor accept downloads of bills, unless certified
as described below: -
Photocopy’s identity documents can be accepted as evidence provided that each copy
document has an original certification by an appropriate person to confirm that it is a true
copy, and the person is who they say they are for standard customer due diligence an
appropriate person is for example a bank, financial institution, solicitor or notary,
independent professional person, a family doctor, chartered accountant, civil servant, or
minister of religion.
The documents must be from a reliable source not connected to the customer.
Bayat Traders Limited check the documents to satisfy yourself of the customer’s identity.
This may include checking.

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 Sources of evi-
dence
List 1: Evidence of identity Acceptable photo identity
✓ Valid passport; or
✓ Valid photo card driving licence (full or provi-
sional); or
✓ National identity card (non-UK nationals issued
by EEA member states and
✓ Firearms certificate or shotgun licence; or
✓ Identity card issued by the Electoral Office for
UK Acceptable non-photo evidence of identity as second
proof of identification
Documents issued by a government department, incor-
porating the person’s name and residential address or
their date of birth. E.g.
✓ A current UK full driving licence old version
(not provisional licences); or
✓ Evidence of entitlement to a authority funded
benefit (including housing benefit and council
tax benefit), tax credit, pension, educational or
other grant; or
✓ Documents issued by HMRC, such as PAYE cod-
ing notices and statements of account (NB:
employer issued documents such as P60s are
not acceptable)
✓ End of year tax deduction certificates.
If a member of our staff has visited an individual at their home address. A record of their
visit may corroborate the individual’s residential address (instead of the need for a second
document). This should be covered in the risk assessment.
Where an agent, representative or any other person acts on behalf of the customer we
ensure that they are authorised to do so, identify them, and verify the identity using
documents from a reliable and independent source.
List 2: Evidence of address or date of birth
✓ Instrument of a court appointment
(such as a grant of probate, bank-
ruptcy); or
✓ Current council tax demand letter
or statement; or
✓ Current (within the last 3 months) bank
statements, or credit/debit card state-
ments issued by a regulated financial
sector firm in the UK, EU or JMSLG
equivalent jurisdiction (but not those
printed off the internet); or
✓ A file note of a visit by a member of the
firm to the address concerning
(“home visit”); or
✓ An electoral register search showing
residence in the current or most re-
cent electoral year
✓ A recent (last available no more than 3
months) utility bill (gas, water, electric-
ity, telephone – not mobile phone
bills); it must be a bill or statement of
account (not correspondence); or
✓ Valid photo card driving licence
(full or provisional); or
✓ A current UK full driving licence
old version (not provisional li-
cences); or
✓ Evidence of entitlement to a state or
a local authority funded benefit (in-
cluding housing benefit and council
tax benefit), tax credit, pension, edu-
cational or other grant; or
✓ Documents issued by HMRC, such as
PAYE coding notices and statements of
account (NB: employer issued
documents such as P60s are not ac-
ceptable);or
✓ A firearms/shotgun certificate; or
✓ A solicitor’s letter confirming re-
cent house purchase or land pre-
vious address).
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Evidence checks for validity
When accepting evidence of identity from a customer, it is important that we make
sufficient checks on the evidence provided to satisfy us of the customer’s identity,
and that we keep a record of the checks made.
Checks on photo ID may include:
▪ Visual likeness against the customer
▪ Does the date of birth on the evidence match the apparent age of the cus-
tomer?
▪ Is the ID valid?
▪ Is the spelling of names the same as other documents provided by the cus-
tomer?
Checks on secondary evidence of ID may include:
Do the addresses match the address given on the photo ID?
Does the name of the customer match with the name on the photo ID?

Individuals not resident in the UK

We should obtain the same types of identity documents for non-UK residents as for UK
residents. If there is any concern that an identity document might not be genuine, contact
with the relevant embassy or consulate is essential. If documents are in a foreign language,
we must satisfy our self that they do in fact provide evidence of the customer’s identity.

Electronic verification
As a secondary proof of Identification, we also screen customers on electronic verification
for those that we cannot have enough proof of identification in hard paper. Electronic
verification must be done using third party software that is registered with the Information
Commissioner’s Office to store personal data. Electronic verification should meet a
standard level of confirmation before it can be relied upon. In circumstances that do not
give rise to suspicion or significant risk of impersonation fraud, the standard level of
confirmation is:
▪ One match on an individual’s full name and current address, and
▪ A second match on the full name and either his current address or his date of
birth.

Politically Exposed Persons (PEPs)

Politically exposed persons are persons that are entrusted with prominent public functions, held in
the UK or abroad. Typically, this includes
• Members of parliament or similar legislative bodies include regional govern-
ments in federalized systems and devolved administrations, including the
Scottish Executive and Welsh Assembly, where such bodies have some form of
executive decision-making powers does not include local government in the
UK, but it may, where higher risks are assessed, be appropriate to do so in
other countries.
• Members of the governing bodies of political parties generally only apply to
the national governing bodies where a member has significant executive
power (e.g., over the selection of candidates or distribution of significant
party funds). political parties who have some representation in a national or

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 supranational Parliament or similar legislative body.
• Members of supreme courts, of constitutional courts or any judicial body the
decisions of which are not subject to further appeal except in exceptional
circumstance this includes judges of the Supreme Court does not include any
other member of the judiciary
• Members of courts of auditors or boards of central banks
• Ambassadors and high-ranking officers in the armed forces where persons
holding these offices on behalf of the UK government are at Permanent Sec-
retary or Deputy Permanent Secretary level, or hold the equivalent military
rank e.g. Vice Admiral, Lieutenant General or Air Marshal
• Members of the administrative, management, or supervisory bodies of state-
owned enterprises this only applies to for-profit enterprises where the state
has ownership of greater than 50% or where information reasonably availa-
ble points to the state having control over the activities of such enterprise
• Directors, deputy directors, and members of the board, or the equivalent of
an international organization. Includes international public organizations
such as the UN and NATO. does not include international sporting federa-
tions

The Regulations require that family members of PEPs must also have enhanced due diligence
measures applied to them. For these purposes, the definition of “family member” includes:
• spouses/civil partners of PEPs.
• children of PEPs and their spouses/civil partners; and parents of PEPs

To comply with regulations, Bayat Traders Limited ensure that all accounts relating to PEP’s
must be
• approved by the MLRO
• Be subject to enhanced due diligence
Customer Behavior
A transaction is suspicious if the customer:
• Splits a single large transaction into small transactions to avoid producing ID also
known as smurfing.
• always send money under the large transaction limit
• offers a legitimate ID which appears to have been altered
• refuses to provide ID or proof of address
• tries to establish conversation with the employee on other subjects to distract you
• doesn’t show any concern about the rates or charges
• doesn’t know how much money he is sending
• has unusual needs or wishes in relation to the transaction
• says he is transferring money for a third party
• is reluctant to give the information requested for proper identification
• Provides an ID document where the photo does not match the customer’s
appearance.
• appears to be unemployed, but regularly carries out large transactions
• is a regular customer without a local address, who appears to reside locally be-
cause he or she is a repeat customer
• offers a tip to process the transaction
• carries out a level of transactions which are inconsistent with his background
• is willing to pay more commission if he doesn’t have to show his passport

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 • comes in with people who ‘hang around’ whilst he does the transaction
• is inquisitive about the company secrecy policy or reporting procedures
• asks what the maximum amount is he can send without providing ID
• seems respectable, but carries money in a plastic bag
• the money contains large number of Scottish notes
• carries out several transactions in a day or week

Sanctions List Check

The UK financial sanctions regime plays an important part in delivering the Government’s
foreign policy objectives. It is also used by the government to prevent and suppress the
financing of terrorism and terrorist acts.
• Any client found on a sanctions list will be declined and no transactions will be
carried out
• Our bespoke remittance software automatically identifies sanctioned entities.

The company has developed a policy to check all transactions to confirm that no
transaction involves any individual or company on the UK Sanctions list. (HM Treasury
Consolidated List). This list is available at: http://hmt-
sanctions.s3.amazonaws.com/sanctionsconlist.htm

In the situation that there is any target match, the transaction would be automatically
frozen, and a report will be made to HM Treasury (Asset Freezing Unit) by the MLRO. The
details of the Asset Freezing Unit are as follows.
Asset Freezing unit
HM Treasury
1 Horse Guards Road
London
Sw1A 2HQ
E-mail assetfreezingunit@hm-treasury.gov.uk
Fax: 02072705430
Tel: 02072705454 or02072705664
The transaction will also be reported to National Crime Agency (NCA).
If and when the company processes USD$ to settle payments, it is company policy that all
beneficiaries of transactions processed in USD$ are verified against the Office of Foreign
Asset Control (OFAC) list. In any case where a target match is found, the transaction will
not be allowed to proceed.

According to regulation 20 of The Money Laundering Regulations 2017 Company maintain

appropriate and risk-sensitive policies and procedures relating to:
• Customer due diligence
• Reporting
• Recordkeeping
• Internal control
• Risk assessment and management
• Monitoring and management of compliance, and the internal communication
of such policies and procedures, in order to prevent activities related to money
laundering and terrorist financing.

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Enhanced Due Diligence (EDD)
Enhanced due diligence applies in situations that are high risk. It means taking additional
measures to identify and verify the customer’s identity and source of funds and doing
additional ongoing monitoring.
We must do Enhanced due diligence when:
• we have identified in our risk assessment that there is a high risk of money laundering
or terrorist financing
• HMRC or another supervisory or law enforcement authority provide in-
formation that a particular situation is high risk
• a customer or other party is from a high risk third country identified by the EU
• a person has given us false or stolen documents to identify themselves
(immediately consider reporting this as suspicious activity)
• a customer is a politically exposed person, an immediate family member or a close
associate of a politically exposed person
• the transaction is complex, unusually large or with an unusual pattern
and have no apparent legal or economic purpose in any case, identified
as one where there is a high risk of money laundering or terrorist financ-
ing—
• By the relevant person under regulation 18(1), or
• In information made available to the relevant person under reg-
ulations 17(9) and 47.
• In any business relationship or transaction with a person established in
a high-risk third country.
• About correspondent relationships with a credit institution or a financial
institution (by regulation 34).
• If a relevant person has determined that a customer or potential cus-
tomer is a PEP, or a family member or known close associate of a PEP
(by regulation 35).
• In any case where the relevant person discovers that a customer has pro-
vided false or stolen identification documentation or information and
the relevant person proposes to continue to deal with that customer; (f)
In any case where—
• a transaction is complex and unusually large, or there is an unu-
sual pattern of transactions, and
• The transaction or transactions have no apparent economic or
legal purpose, and in any other case which by its nature can pre-
sent a higher risk of money laundering or terrorist financing.

Situations that are high risk

• You have identified in your risk assessment that there is a high risk of money
laundering or terrorist financing
• HMRC or another supervisory or law enforcement authority provides information

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 that a particular situation is a high risk
• A customer or other party is from a high-risk third country identified by the EU
• A person has given you false or stolen documents to identify themselves (imme-
diately consider reporting this as suspicious activity)
• A customer is a politically exposed person, an immediate family member, or a
close associate of a politically exposed person
• The transaction is complex, unusually large, or with an unusual pattern and has no
apparent legal or economic purpose

Below are the cased when its mandatory to perform the EDD as per HMRC Guidance
• If we are considering out business to be High Risk depending on the factors
identified in Risk Assessment
• HMRC or another supervisory or law enforcement authority provide infor-
mation that a particular situation is high risk
• a customer or other party is established in, or operates in a high risk third
country identified by the EU, FATF or HMT
• person has given you false or stolen documents to identify themselves (im-
mediately consider reporting this as suspicious activity)
• a customer is a politically exposed person, an immediate family member or
a close associate of a politically exposed person
• the transaction is complex, or unusually large, or with an unusual pattern
and have no apparent legal or economic purpose
• a customer is a third country national who is applying for residence rights
in or citizenship of an EEA state in exchange for transfers of capital, pur-
chase of a property, government bonds or investment in corporate entities
in that EEA state.
• Unusual aspects of a business relationship
• a person is resident in a high-risk area
• use of a legal person or arrangement used to hold personal assets
• a company with nominee shareholders or shares in bearer form
• a person or business that has an abundance of cash
• an unusual or complex company structure given the nature of the type of
business
• the transaction involves private banking
• the transaction favors anonymity
• payment from third parties with no obvious association
• involves nominee directors, nominee shareholders or shadow directors, or
a company formation is in a third country

How do we apply Enhance due diligence?

If enhanced due diligence is appropriate, then we must do more to verify identity and scrutinise the
background and nature of the transactions than for standard customer due diligence, for example at
least we:

Page 32 of 53
 • obtain additional information or evidence to establish the identity
• take additional measures to verify the documents supplied, or require certification by a bank,
financial institution, solicitor or notary
• ensure the first payment is made through a bank account in the name of the customer
• take more steps to understand the history, ownership, and financial situation of the parties to
the transaction
• establish the source of wealth and source of funds
• carry out more scrutiny of the business relationship and satisfy yourself that it is consistent
with the stated purpose

Non – compliance with customer due diligence

If we find that customer is not complying while performing the customer due
diligence measures, then we do not.
• Carry out a transaction with or for the customer
• Establish a business relationship or carry out an occasional transaction with the customer.
• Terminate any existing business relationship with the customer
• Consider making a suspicious activity report
• If no suspicious activity report is made, record the reasons why it is considered
that a report is not required

What is business relationship

A business relationship exists where the company sets up a process with the customer
which makes it easier for them to make regular transactions. It is our company policy
that a business relationship exists in one of the following situations:
• a unique customer number is allocated, and a customer registration form is
completed
• a loyalty card is issued
• customers can make transactions over the internet

In situations where a business relationship exists, there is an obligation to obtain a

proof of ID, plus confirmation of purpose of transaction and source of funds. There is
an obligation on the company to monitor all transactions carried out in the business
relationship (see transaction monitoring).
Customer Account
Any customer who is desirous of remitting the money through Bayat Traders Ltd has necessarily
to first open a regular/formal account with us. This account opening by our customer is essential,
because our IT system being used does not allow anyone to undertake even a single transaction
without first opening of an account with Bayat Traders Ltd. The system needs recording of the
required details about the customer; [Know Your Customer (KYC)] and exercising of due diligence
with respect to the transaction and the person who is desirous of undertaking the transaction.

Account opening terms and conditions

The dealing staff member of Bayat Traders Ltd should first himself/herself read and fully understand the
procedures and Terms and Conditions that are applicable to opening of an account by a customer
with the Company.

While opening of an account of a customer it is essential that the dealing staff member:
✓ Must explain in detail to the client all the Terms and Conditions that are applicable in the

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 case of the opening of an account with Bayat Traders Ltd for undertaking remittance of
money. (These Terms and Conditions are already available in the software and in hard copy
with which all staff members must familiarise themselves and seek clarifications where these
are required.
✓ All the applicable Terms and Conditions and applicable Rules and Regulations must be ex-
plained in detail to every customer before opening of their account.
✓ After acceptance of the Terms and Conditions by the customer, the concerned staff
member will open an account for the customer after filling all the necessary fields in
the account opening form. After completing the form, the concerned staff member must
click on ‘Terms & Conditions (T&C)’ tab, on his computer screen; this command will allow
the software to automatically generate a specific account number that will be unique to
the customer concerned. Simultaneously a ‘T&C form’ will be generated by the system for
the acceptance and signatures of the customer; the staff member should witness the signa-
tures on the forms by the customer.
✓ It is only after the above stated Conditions have been met that the system will generate
a separate and unique account number for each customer.
✓ When a new Account is being opened the ‘Terms and Condition Form’ should be filled in
completely and no blanks spaces should be left. The ‘Terms and Conditions form’ must
always be signed by the account holder in front of the staff member who is opening the ac-
count. The staff member accepting the customer for opening of the account will also counter
sign the acceptance by the customer of the Terms and Conditions as a certification of his wit-
ness to the fact that the customer came to the office in person, opened the account and ac-
cepted the applicable Terms and Conditions of operating the account.
✓ No Account will be opened in case the customer is not present in person irrespective of
the reasons. Bayat Traders Ltd does not open any non- face-to-face account under any
circumstances.
✓ Customer must be present physically with original form of ID when he wishes to open an
account with us.
✓ The Identification Document (ID) must be seen in original by the dealing staff member.
Corporate customers
For corporate entities and sole traders, we must obtain and verify identity information that is relevant
to that entity. This includes:
• the full name of the company
• company or other registration number
• registered address and principal place of business
For private or unlisted companies, we must take reasonable steps to obtain and verify:
• country of incorporation
• names of the members of management body, or if none, its equivalent and the name of the
senior person responsible for the company
It will also be necessary to establish the beneficial owners of such entities, that is, for private or
unlisted companies, the names of all directors (or equivalent), and the names of individuals who own
or control over 25% of its shares or voting rights - or the names of any individuals who otherwise
exercise control over the management of the company. You must verify the identity through reliable,
independent sources that are relevant to that type of entity. For example:
• searching a relevant company registry
• obtaining a copy of the company's certificate of incorporation
Where an individual claim to act on behalf of a seller or buyer, we must also obtain evidence that the
individual has the authority to act for them, identify the individual and verify the identity. Corporate
bodies in the UK, who are not listed on a regulated market, have obligations to keep a register of
people with significant control (a PSC register) and must provide this information when requested.

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When a corporate person enters into a transaction with Bayat Traders Ltd we can request that they
provide us with the following information:
• name, registered number, registered office and principal place of business
• names of the board of directors or equivalent body
• names of the senior person responsible for its operations
• the law to which it is subject
• its legal and beneficial owners
• its memorandum of association or similar documents
Guidance on the requirements to maintain PSC registers is available at:
https://www.gov.uk/government/publications/guidance-to-the-people-with-significantcontrol-
requirements-for-companies-and-limited-liability-partnerships
This information will assist in identifying beneficial owners, but it will not provide you with all the
information you need to verify their identity, for example, the address or date of birth of the
individual.
Trustees have similar obligations to tell you that they are acting as a trustee, to identify all of the
beneficial owners of the trust and any other person that may benefit. The customer must notify us of
any changes to the information supplied.

Existing Account Holders Terms and Conditions

Every customer who already has established an account with Bayat Traders Ltd should strictly
abide by the applicable Terms and Conditions. The dealing staff must ensure, when undertaking a
transaction, that the records are available in the system of an existing customer along with
acceptance of the ‘Terms and Conditions’ by him are complete and updated in all respects.

Change and modification to client details

All customers should be made aware that information is held for 5 years – random checks may be made
on information supplied and if any details are incorrect, customers will be suspended from the system
until the customer supplies the updated personal information. Staff should particularly take care to
make sure that customer ID information previously supplied is still valid (and that ID documents have
not expired). Any customer address information provided should be re-verified at least every twelve
months.

Business Monitoring
It is the responsibility of the MLRO to monitor all the activity of the business with particular reference
to the potential financial crime risk. The MLRO will keep a close eye on the following criteria and
provide a report to senior management when required.

The report is likely to include commentary on the following issues (in the case that there is no
information to report, there should be a ‘nil return’ should be indicated):
• Confirmation that adequate CDD information is being collected and that on-
going monitoring is taking place
• Summary data relating to complex or unusual transactions
• Number of internal consents/SARs received from staff members
• Number of SARs made to National Crime Agency
• Information on status of staff training within the company
• Confirmation that all business records have been stored

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 • Changes in the law/operating environment which are or will impact the business
• Changes in risk matrix effecting the business
• Contacts with the regulator Reports should normally be written.

The MLRO should indicate where there is action of the regulator, law enforcement
or other agency which raises any potential issues for the business.

The MLRO will, as a matter of policy, submit an annual report to the board of directors.

Transaction Processing
When a retail customer makes an approach in person to the company with a request
to transfer funds, he or she details (Names, DOB, Post code) etc is collected and
inputted into the system. (See below) also information about the sending customer
and the beneficiary. This information is recorded by the cashier in the Company's
money transfer software.

Upon completion of the transaction, the customer is offered a receipt which records
all the details of the transaction.

The company will keep complete records for each transaction showing the following:
• Unique transaction number
• Sending customer ID number (generated by the company)
• Sending customer name
• Sending customer address (including full postcode)
• Sending customer telephone number
• Transaction amount
• Exchange rate
• Fee charged
• Pay out bank account
• Receiving customer name (if available)
• Receiving customer address (if available)
• Receiving customer telephone (if available)

All customers will need to be made aware that they should make a complaint to the business in the
first instance if they are not happy with any aspect of the way the transaction has been processed.
Any complaint must be processed in line with the complaints handling process established by the
business (see complaints handling policy).

Transaction Monitoring
The number and volume of transactions going through the company will be monitored, together with
scrutiny of transactions, according to risks parameters relating to customers, products, delivery
channels and geographical area of operation.

The MLRO will keep under review all the transactions which are being processed by each customer.
This means the MLRO will:
• review on a daily, weekly, and monthly basis whether the volume of transactions which is
being processed by the customer is consistent with what was anticipated when the cus-
tomer was registered
• keep a watch out for a sudden increase in business from an existing customer
• look out for uncharacteristic transactions which are not in keeping with the customer’s

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 known level of activity
• look out for peaks of activity at locations or at particular times
• look out for unfamiliar or untypical types of customers or transaction
• look out for transactions related to potential sanctions list matches or PEP’s

To assist with transaction monitoring, the company has defined a transaction monitoring
protocol (see appendix).

Linked Transactions
Linked transactions may be a series of transactions by a legitimate customer, or they may be
transactions that appear to be independent but are in fact split into two or more transactions to avoid
detection. This typically happens when a customer tries to avoid anti-money laundering controls by
splitting transactions into several smaller amounts, below the level at which checking ID or enquire
about the source of funds. Bayat Traders Ltd is using a system which can detect linked transactions,
and to undertake enhanced due diligence on them, and report any suspicious activity when they're
detected. The value of the transaction here means the gross value of the transaction, not the value of
the commissions, fees, or charges. Our system can associate a series of money exchanges made by
the same customer over a period. In the event that ‘linked’ transactions are identified, they should be
notified to the MLRO who will determine whether or not there are any suspicious circumstances which
mean the transaction should be reported to NCA

Suspicious Activity and Report

What is suspicious activity (which must be reported)?
The law requires staff working in financial sector businesses to be on the lookout not
only for suspicious transactions, but also for any activity which takes places around
a potential transaction.
Suspicion is personal and subjective and falls far short of proof based on firm evidence.
Two examples are given below from a recent court case (K Limited v National
Westminster Bank) in which the judge gave some helpful guidance on what
suspicion is:
A person who considers a transaction to be suspicious would not be expected to
know the exact nature of the criminal offence or that the particular funds were
definitely those arising from the crime.
At the same time, the employee should take extra care with transactions done by
new customers that do not make any sense or one that seem abnormal. (E.g., a
known unemployed person sending a large amount of money)

Suspicion Indicators
The following lists are provided for staff as an aid to whether a particular transaction may be
suspicious. The list is not exhaustive, and staff should consider all the circumstances of a particular
transaction before deciding whether to report any issues to the MLRO.
New customers and occasional or “one-off” transactions:
• Checking identity is proving difficult.
• The customer is reluctant to provide details of their identity.
• There is no genuine reason for the customer using the services of an MSB.
• A cash transaction is unusually large.
• The cash is in used notes and/or small denominations.
• The customer requests currency in large denomination notes.

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 • The customer will not disclose the source of cash.
• The explanation for the business and/or the amounts involved is not credible.
• A series of transactions are structured just below the regulatory threshold for due diligence
identity checks.
• The customer has made an unusual request for collection or delivery.
• Transactions having no apparent purpose, or which make no obvious financial sense, or which
seem to involve unnecessary complexity.
• Unnecessary routing of funds through third parties.
Regular and established customers.
• The transaction is different from the normal business of the customer.
• The size of frequency of the transaction is not consistent with the normal activities of
the customer.
• The pattern of transactions has changed since the business relationship was established.
• Money transfers to high-risk jurisdictions without reasonable explanation, which are not con-
sistent with the customer’s usual foreign business dealings.
• Sudden increases in the frequency/value of transactions of a particular customer without
reasonable explanation.
Examples where customer identification issues have potential to indicate suspicious activity.
• The customer refuses or appears reluctant to provide information requested.
• There appears to be inconsistencies in the information provided by the customer.
• The customer’s area of residence is inconsistent with other profile details such as employ-
ment.
• An address appears vague or unusual.
• The supporting documentation does not add validity to the other information provided by
the customer.
• The customer is in a hurry to rush a transaction through, with promises to provide the infor-
mation later.
Examples of activity that might suggest to staff that there could be potential terrorist activity.
• The customer is unable to satisfactorily explain the source of income.
• Frequent address changes.
Media reports on suspected or arrested terrorists or groups.

Suspicious activity report (SAR) – internal company process

In the situation that an employee, (for this purpose, collectively, staff members) has
suspicions about a customer and/or transaction, he must ensure that the company
MLRO is notified about his suspicions as soon as possible.

Staff should use the internal ‘Suspicious Activity Report Form’. The SAR should
contain as a minimum the following information:
• Date/time of transaction
• Amount
• Customer name/customer ID information (e.g., passport number, etc.)
• Transaction number
• Reason for suspicion of transaction

If in doubt, the staff member should call the MLRO to discuss the reasons for their
suspicion – however, they should be careful not to do this whilst the customer is
standing in front of them (they may ‘tip off’ the customer otherwise, see below).

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 In the situation where the staff member works for an agent, the report should be
made in the first instance to the Agent MLRO, who must then report on to the
company MLRO.

The timing for submitting the internal SAR is important. The law states that an
individual working in the regulated sector (i.e. a money transfer company) should
make a report as soon as he or she becomes suspicious. This may mean either
before the transaction takes place or immediately afterwards.

Where a staff member becomes aware that a customer wants to carry out a
transaction which is suspicious and the timing for the transaction allows it, the staff
member must ensure that ‘consent’ is given before processing the transaction.
‘Consent’ means that the company has sought and obtained approval from the
Financial Intelligence Unit at the National Crime Agency (NCA) to process the
transaction. Further information on ‘seeking consent’ is provided below.

However, staff may decide that there would be a danger that if they were to seek
consent for a particular transaction (i.e. in advance of the transaction taking place)
that there might be a danger that the customer would be ‘tipped off’. See below for
more information on ‘tipping off’.

All staff members will have fully discharged their duties, and will have the full
protection of the law, once a report of their suspicions has been made to the
company MLRO.

Once the MLRO receives the internal SAR from the staff member, the MLRO
has two options:
• Report the SAR on to National Crime Agency (see procedure below)
• File an internal note indicating why, based on review of the circumstances
around the transaction, it is judged not necessary to make a report to NCA

The MLRO should complete the MLRO SAR Resolution form (see appendix for
sample) in the event he decides not to make a report to NCA

Making a suspicious activity report (SAR) to NCA

A suspicious activity report (SAR) is the name given to the making of a disclosure to
NCA under either Proceeds of Crime Act or the Terrorism Act. NCA has issued a
preferred form to be completed when making a SAR, which may become mandatory
in the future. NCA encourages firm to start using the preferred form now.

Preferably, firms should use SARs On

line (http://www.nationalcrimeagency.gov.uk/contact-us/reporting-suspicious-
activity-sar) where you have computer access. This securely encrypted system
provided by NCA allows firms to:
• register the firm and relevant contact persons
• submit a SAR at any time of day
• receive e-mail confirmations of each SAR submitted

SARs can still be submitted in hard copy, although they should be typed and on the

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 preferred form. Firms will not receive acknowledgement of any SARs sent this way.

Hard copy SARs should be sent to: Fax: 020 7238 8256 or by post to: UK FIU, PO Box
8000, London SE11 5EN
The Financial Intelligence Helpdesk can be contacted on 020 7238 8282. Firms can
contact NCA on this number for:
• help in submitting a SAR or with the SARs online system
• help on consent issues
• assessing the risk of tipping off so you know whether disclosing infor-
mation about a particular SAR would prejudice an investigation

NCA is required to treat any SARs confidentially. Where information from a SAR is
disclosed for the purposes of law enforcement, care is taken to ensure that the
identity of the reporter and their firm is not disclosed to other persons.

It is our company policy that only the MLRO can submit a SAR to NCA. It is expressly
forbidden for employees to make a SAR direct to NCA.

Seeking ‘consent’
Staff may encounter situations when processing a transaction where a request
needs to be made to NCA ‘seeking consent’ to undertake acts which would be
prohibited as a principal money laundering offence. The idea behind consent is
that the company is seeking a permission to proceed with the transaction before
the transaction is finally processed.

NCA has up to 7 days to confirm whether the transaction for which a consent has
been requested can proceed – until NCA give consent, the transaction cannot
proceed – it is frozen. In these circumstances, the staff member must be very
careful that they do not ‘tip off’ the customer about the reason for the delay in
processing the transaction.

Where NCA gives notice that consent to a transaction is refused, a further 31-day
period (the “moratorium”) commences on the day that notice is given. The 31 days
include Saturdays, Sundays, and public holidays. It is an offence to undertake the
act during this period as the participant would not have the appropriate consent.
The moratorium period enables NCA to further their investigation into the reported
matter using the powers within Proceeds of Crime Act (POCA) in relation to the
criminal property (e.g., imposing a restraint order). If the moratorium period
expires and no such action has been taken, the reporter is free to proceed with the
act(s) detailed in the initial disclosure.

It is company policy that all requests for consent must be processed through the company MLRO – it
is expressly forbidden for employees to make a ‘consent’ request direct to NCA

Staff training and awareness

The policies and procedures contained in this manual depend to a large extent of
the Bayat Traders Limited staff to Money Laundering effectively. All employees are
made aware of their responsibilities under the Proceeds of Crime Act and the
Terrorism Act to report knowledge or suspicion to the Nominated Officer and the

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 requirements under MLR 2019 for the business to apply customer due diligence
measures. All employees receive refresher AML on-going training to make aware of
changing behavior and practices amongst money launderers and those financing
terrorism. A range of information is available on the internet and through the media,
for example, the website of the Financial Action Task Force www.fatf-gafi.org.
• The identity and responsibilities of the MLRO
• The potential effect of any breach of the law on the firm, its employees per-
sonally and its clients
• The risks of money laundering and terrorist financing that the business faces
• The vulnerabilities of the business’s products and services
• The policies and procedures that have been put in place to reduce and man-
age the risks
• Customer due diligence measures, and, where relevant, procedures for moni-
toring customers’ transactions
• How to recognise potential suspicious activity
• The procedures for making a report to the Nominated Officer
• The circumstances when consent is to be sought and the procedure to follow
• Reference to industry guidance and other sources of information, e.g., NCA, FATF.

Each member of Bayat Traders Limited staff is always ready to deal with the risks
posed by their role. Their regular training keeps their knowledge and skills up to date.
It covers: -
• The staff member’s duties
• The risks posed to the business
• The business policies and procedures
• How to conduct customer due diligence and check customer’s documents
• How to spot and deal with suspicious customers and activity
• How to make internal reports, including disclosures of suspicious activity data
protection requirements
• Record keeping
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information
on the Payer)
• Regulations 2017: Part 7 of the Proceeds of Crime Act; and section 18 and 21A
of the Terrorism Act

Bayat Traders Limited impart Training to its employees and in one or the other
following ways to keep their knowledge up to date.
• Face to face training through external advisors
• Online training through external advisors
• HMRC webinars
• Reading publications
• Meeting at regular intervals to look at the issues and risks

All staff must be aware of their own personal obligations as they can be held liable for failure to
report suspicious transaction to the MLRO.

Customer complaint procedure

At Bayat Traders Limited each of our customers are important to us, and we believe

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 you have the right to a fair, swift, and courteous service always. Bayat Traders Limited
has established a complaints procedure to ensure your complaint is dealt with
promptly, efficiently, in a positive manner, and by the correct person. As our customer,
you are in a good position to judge how we are performing, and we need you to tell
us if things have gone wrong. We treat your complaint seriously and in confidence.
This leaflet sets out the complaint procedures you should follow. However, please
bear in mind that as we must work within a framework set by law. Any decisions we
make must be in line with relevant laws, we may not always be able to meet your
expectations.

Procedure
If you are not satisfied with the service you have received, please get in touch with the
person executing the deal to which your complaint refers. They can deal with most
complaints informally and quickly.
If you prefer to make a formal complaint, such complaints must be made in writing,
by post or e-mail, and addressed to the Director/MLRO. The Director/MLRO is keen
to put the matter right (if they can) and to learn from any mistakes that may have
been made.
Bayat Traders Ltd
363 Ballards Lane
North Finchley
LONDON
N12 8L J
UNITED KINGDOM
Please provide as many details as you can in your complaints. All letters you receive
from us give the contact details of the person who sent them, and usually a reference
number.
To help us investigate and resolve the problem as quickly as possible, whether you
wish to resolve it informally or you are making a formal complaint, please make sure
you always give us the following information:
● Full name and address.
● Your transaction reference number (if your complaint relates to a
particular transaction).
● Your daytime phone number (if possible); and
● Full details of your concern or complaint, including any previous deal-
ings with us about it.
● Copies of any relevant documents such as letters.
● Details of what would you like us to do.

We acknowledge the receipt of your complaint in writing within 48 hours and confirm
who handles your complaint, and how you can contact them.
We shall investigate your concerns and respond to you promptly and at the latest
within 15 days of receipt of the complaint. In exceptional situations, if the answer
cannot be given within 15 business days for reasons beyond our control, we send a
holding reply, clearly indicating the reasons for a delay in answering the complaint
and specifying the deadline by which we receive the final reply. In any event, the
deadline for receiving the final reply shall not exceed 35 business days.
In our final response we include:
● Summary of the complaint.
● A summary of the outcomes of your investigation.

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 ● Whether we acknowledge there has been any fault on our part and
whether the complaint is upheld.
● Details of any offer to settle the complaint and the duration of the offer.
● If you are a retail client, a notification of your right to refer to
the Financial Ombudsman Service.
If you are not satisfied with the Complaints Handling, you can write to The Financial Ombudsman
Service (FOS) - Alternative dispute resolution at
The Financial Ombudsman Service (Fos),
Exchange Tower
London E14 9SR
Tel No: 0800 023 4567 or 0300 123 9123
Online compliant form: https://help.financial-ombudsman.org.uk/help
If you are not satisfied with the Complaints Handling, you can write to The Financial Ombudsman
Service (FOS).

Record Keeping
The purpose of The Money Laundering, Terrorist Financing and Transfer of Funds
Regulations 2017 on record keeping is to require a business to be able to demonstrate
its compliance with The Money Laundering, Terrorist Financing and Transfer of Funds
Regulations 2017, through keeping evidence and records of due diligence checks
made and information held on customers and transactions. These records may be
crucial in any subsequent investigation by NCA, the police, or HMRC. They enable the
business to produce a sound defense against any suspicion of involvement in money
laundering or terrorist financing, or charges of failure to comply with the regulations.

The record that must be kept

The records that must be kept are:
● Copies of the evidence obtained of a customer’s identity for five years after the end of
the business relationship
● Details of customer transactions for five years from the date of the transaction
● Details of actions taken in respect of internal and external suspicion reports
● Details of information considered by the nominated officer in respect of an
internal report, where the nominated officer does not make a suspicious
activity report
● Copies of the evidence obtained if we are relied on by another person to carry
out customer due diligence, for five years from the date of the agreement, the
agreement should be in writing

We also maintain:
● a written record of our risk assessment
● a written record of our policies, controls, and procedure

Transaction and business relationship records (for example, account files, relevant
business correspondence, daily logbooks, receipts, cheques, and so on) should be
maintained in a form from which a satisfactory audit trail may be compiled, and which
may establish a financial profile of any suspect account or customer.

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How long the customer due diligence records must be kept?
We keep records of customer due diligence checks and business transactions:
● for 5 years after the end of the business relationship
● for 5 years from the date, an occasional transaction was completed
● we should also keep supporting records for 5 years after the end of
a business relationship
● we should keep records from closed branches or agents

The records should be reviewed periodically to ensure, for example, that a

fresh copy of expired documents is held.

Our risk assessment and policies, controls, and procedures must be kept up to date
and be amended to reflect any changes in our business.
In what format must the records be kept?
Most businesses want to keep to a minimum the volume and density of records that
need to be kept whilst still complying with the Regulations.

Records may therefore be kept:

• By way of original documents
• By way of good photocopies of original documents
• On microfiche
• In scanned form
• In computerised or electronic form.

After the period above the records can be deleted unless we are required to keep
them in relation to legal or court proceedings. We do not require to keep them for more
than twenty- five years.
All electronic records must be submitted to regular and routine backup with offsite storage.

Privacy & Data Protection

Bayat Traders is committed to ensuring that the customer personal data is used correctly and in
accordance with the highest standards of Data Protection Law.
For the purposes of Data Protection Law, Bayat Traders will be deemed a Controller of client’s
personal data.

What personal data do we collect?

Information clients provide us when they use our Services or contact our team

• Details such as clients name, gender, address, date of birth, telephone number, email
address and social security number.

• If clients have a Bayat Traders online account, your login details such as your username,
password, passcode, security question and answers.

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 • All the documents which our customers provide to prove their age or identity so we can
satisfy our KYC (Know Your Customer) checks. For example, government issued ID, passport,
driving licence, marriage certificate and utility bill.

• Copies of documents provide to prove source of funds. For example, bank statement or
payslip.

• Bank account details.

• Personal details of payees (Beneficiary Details)

• Details of the transactions carry out when using our Services, including geographic location
from which the transaction originates.

• In relation to our websites, we will log your Internet protocol (IP) address so that it
recognised next time you visit.

• CCTV Images at Bayat trader’s office.

When Bayat Traders collect personal dada about customers?

• When the clients visit any of our websites or download and install the Bayat Traders app.

• When they make an enquiry about our Services or open an account with us online, over the
telephone, by post or in person.

• When they ask us to provide our Services?

• When they make international payments online, over the telephone, by post or in person.

• When they reserve or purchase foreign currency with us online or in person at the branch.

• When they enter a competition or take up a promotional offer.

• When they sign up to receive our daily brief, whitepapers, and other general marketing from
us.

• When they sign up to receive rate alerts from us.

• When they register for one of our webinars.

• When they have given a third-party permission (e.g., a Referring Partner) to share with us
their personal data.

• When they report a problem, make a query, or issue a complaint about our Services.

• When they visit Bayat Traders branch, they may be recorded on CCTV.

• During correspondence with Bayat Traders employees (or persons acting on our behalf) over
telephone, email, post or in person.

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How do we use the client personal data?
We may process your personal data for the following purposes, depending on how you interact with
us.
To complete the delivery of our foreign exchange, bank, international payment, and wholesale
banknote services.
Without your personal data, we would not be able to open your Bayat Traders account, facilitate
your foreign exchange transactions and complete the delivery of our services.
At the start of the relationship, Bayat Traders may also call or email you to discuss the reasons for
opening an account and your foreign exchange needs. We will do this on the basis of our legitimate
interests.
When they login into your Bayat Traders Account online, we will send them, via SMS or email, a one-
time password as part of our two-factor authentication login process. We will do this to comply with
our legal and regulatory obligations.
Throughout the relationship, Bayat Traders may also be required to send them communications
known as ‘service messages’ in order to inform you about changes to the services we provide them.
For example, changes to our terms and conditions and/or privacy policy, changes to our opening
hours and bank account details, reserve and collect order confirmations and proof of payment
confirmations and other information which is the customer right to be informed.
These service messages will not include any promotional content and cannot be unsubscribed
from.
To comply with Bayat Traders legal and regulatory obligations
In order to meet our legal and regulatory requirements, we are required to carry out regulatory
checks in order to prevent and detect fraud, money laundering, identity theft and other crimes.

Telephone and Email Recording

Telephone calls made and received by Bayat Traders may be recorded and internally monitored for
the purposes of:
1. Ensuring that Bayat Traders complies with its regulatory obligations.

2. Evidencing your use of our Services.

3. Investigating complaints.

4. Gathering evidence in disputes.

5. Improving Bayat Traders’ services (training and quality control).

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Bayat Traders may also maintain a record of all emails sent by or to Bayat Traders for the same
purposes.

Who do we share the customers personal data with?

We may share the customers personal data with the following entities for the purposes described in
this Policy.
Third party service providers
This includes:
• Agencies who provide credit referencing, identity & verification checks, adverse media
checks, sanction screening, PEP checks and fraud prevention services.

• Auditors and professional advisers such as lawyers and consultants.

• Banks and financial services who facilitate our foreign exchange transactions.

• Companies who host, support, and maintain our website, databases, archives and other
business systems.

• Companies who provide off-site hard copy information management facilities.

• Companies who provide Bayat Traders with its customer relationship management
applications.

• Companies who provide Bayat Traders with its customer relationship management
application.

• Companies who perform functions on our behalf in the areas of IT development, IT support,
back office, compliance, and finance.

• Companies that provide our email archiving and backup system.

• Companies that provide our telephone call recording system and tracking analysis software.

• Companies that carry out our direct marketing and research survey emails and texts.

• Companies that provide our online live chat platform.

• Companies who assist with providing our two-factor authentication security process.

• Companies that provide our online electronic signature software.

• Companies that provide our refer-a-friend programme.

• Companies that enable Bayat Traders to collect customer reviews of its Services.

• Companies that provide our customer rewards and incentive scheme.

• Companies that provide Bayat Traders with its appointment scheduling software.

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 • Companies that provide Bayat Traders with its webinar platform.

• Cash-in-Transit Carriers (wholesale banknote clients only).

Public authorities & Regulatory Bodies

This will only be in response to lawful requests made from public authorities, regulatory bodies and
law enforcement in order to meet national security, public interest and/or our legal and regulatory
obligations.

Sharing the customers personal data outside of the UK.

To facilitate our global operations, the personal data that we collect from you may be transferred to,
and stored at, destinations both in and outside the UK.
Where processed outside the UK, we will take appropriate steps to ensure their personal data still
receives a level of protection that is consistent with UK and European data protection standards.

How does Bayat Traders protect the customers personal Data?

Here at Bayat Traders we have put in place appropriate security measures to prevent their personal
data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed.
Personal data is protected by a defence in depth security programme that is aligned to best practice
found in international organisation. network segmentation, standard security appliances (firewalls,
IPS, AV, monitoring via SIEM), secure configuration and system hardening, monthly vulnerability
assessments and yearly penetration tests, documented processes, and procedures, DLP protection,
rogue detection, and monthly rolling patch management and vulnerability remediation. Payment
card information is tokenized to ensure it is protected. We also secure access to all transactional
areas of our websites and apps using ‘https’.
We provide our employees with training and detailed information about our data handling practices
through internal company policies such as our Data Protection Policy. All employees must certify
that they have read and understood the contents of our Data Protection Policy where is reviewed
and updated on an annual basis. As well as our data protection policy, which governs how we
process data throughout the Bayat Traders.

For how long Bayat Traders keep the customers personal Data?
In accordance with our legal and regulatory obligations (for example, Money Laundering Regula-
tions), we will retain the customers personal data for a period of five years from the end of your re-
lationship or last transaction with us.

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 Appendix A- Threshold Money Transfer
Money Transfer

One – off Transaction Thresholds

Thresholds in GBP ID Requirements
£1 to £3,000 1 Photo ID with address or date of birth
£3,001 to £6,000 1 Photo ID and Proof of Address (separate)
£6,001 to £12,000 2IDs and Source of Fund documents/ Declaration form
Above £12,000 2IDs and Source of Fund documents and EDD

Linked Transaction Thresholds

Both Cash and Bank Transactions
Duration Thresholds in GBP ID Requirements[Both Cash and Bank Transactions]
£1 to £3,000 1 Photo ID with address or date of birth
£3,000 to £6,000 1 Photo ID and Proof of Address (separate)
£6,000 to £12,000 2IDs and Source of Fund documents/ Declaration form
Above £12,000 2ID and Source of Fund documents and EDD

Note:
Basic Information: Sender details: Full Name, current residential address, date of birth, Phone no, Profession; Receivers
Details: full name, phone no, Relationship, Purpose of money sending.

1st form of ID: UK Full Driving License, Provisional License+ Counter Part, Valid UK Visa with work Permit, International
Passport with UK Valid Visa, British Passport.

2nd form of ID:*UK Driving License+ Posted Recent Bank Statement/UK Passport/Utility Bills of Gas/Electricity/Water/Council
letter. (No Private company’s bills or letter I.e. Phone Bills.)

Declaration of Fund: Self Declaration in specified Form from Company.

Source of Fund: Written documents showing the sale of legal asset, his/her pay slips/ Bank Statement that showing the
income either salary, Sale of asset that matches or is near to the amount being transferred.

EDD: Further information: EDD applies for situations that are high risk, taking additional measures to identify and verify the
customer’s identity and source of funds and doing additional ongoing monitoring. Purpose and Use of the Fund: Any letter
or Documents from firm/lawyer/accountant/asset Buyer/ Government Departments indicating the purpose and Use of Fund.

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 Guidelines: FCA and HMRC ML Guidelines and Company MLR policy to be followed + Customer Due Diligence with every
customer.

Appendix B- Threshold Bureau De Change

Money Exchange
Buying/ Selling

One - off Transaction Thresholds

Thresholds in GBP ID Requirements
Up to £3,000 No ID but Basic Information
£3,001 to £6,000 1 Photo ID and Proof of Address
£6,001 to £10,000 2IDs and Source of Fund documents/ Declaration form
Above £10,000 2IDs and Source of Fund documents and EDD
Buying High Denomination Note

Linked Transaction Thresholds

Both Cash and Bank Transactions
Duration Thresholds in GBP ID Requirements [Both Cash and Bank Transactions]
Within 3 Months Up to £3,000 No ID but Basic Information
(minimum rolling 90- £3,000 to £6,000 1 Photo ID and Proof of Address (separate)
day period) £6,000 to £10,000 2IDs and Source of Fund documents/ Declaration form
Above £10,000 2ID and Source of Fund documents and EDD

Buying High Denomination Note

Thresholds ID Requirements
Buying High denomination notes equivalent to or below £2,500 1 Photo ID
Buying High denomination notes equivalent to £2,500 to £4,500 2IDs and Source of Fund documents
Buying High denomination notes equivalent to €5000 or above - is prohibited to buy.
Selling High Denomination Notes such as €200, €500 notes are strictly prohibited

Note:

Basic Information: Full Name, current residential address, date of birth, Phone no, of the customer.

1st form of ID: (Photo ID) UK Full Driving License, Provisional License, Valid UK Visa with work Permit, International Passport
with UK Valid Visa, British Passport.

2nd form of ID: (Proof of Address) UK Driving License, Posted Recent Bank Statement/UK Passport/Utility Bills of
Gas/Electricity/Water/Council letter. (No Private company’s bills or letter I.e. Phone Bills.)

Source of Fund: Written documents showing the sale of legal asset, his/her pay-slips/ Bank Statement that showing the
income either salary, Sale of asset that matches or is near to the amount being transacted.

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EDD: Further information: EDD applies for situations that are high risk, taking additional measures to identify and verify the
customer’s identity and source of funds and doing additional ongoing monitoring.

Guidelines: HMRC Anti-Money Laundering Supervision: Money Service Business guidelines (The Money Laundering and
Terrorist Financing (amendment) Regulations 2019 (MLRs)) and Company AML policy to be followed.

Appendix C- International SAR Format

SUSPICIOUS ACTIVITY REPORT FORM (INTERNAL)

SAR No: ............./..............

Particulars Remarks
Date:
ID of the customer:
Name/address of Customer:

Telephone no of Customer:
Nature of suspicious activity:
Give full detail of suspicion:
[Include detail of transactions and identity
checks.]

Attach any relevant documents:

1. Transaction receipts Yes /No
2. Proof of ID and Address
3. Sanctions list checks/Credit Check
Name of the Reporting Officer:
Signature by Reporting Officer:

Refer to NCA: [To be completed by MLRO] Yes/ No

Do not refer to NCA:

Reason for decision: Details

Date referred to NCA:

Approved By: ..........................................

MLRO

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Appendix D- Large Transaction Declaration
Transfer/Exchange

Large Transaction Approval and Declaration Form

Required for transactions with high risk, high denomination or for Exchange in excess of £12,000- One-Off or
Linked Transactions, this form is filled with the attachment of source of fund documents.

Date: ____________________
Amount to be Exchange One Off: £………………………

Linked/Regular: £…………………….
Customer’s Information:
Details Remark
Name customer
Customer ID
Occupation of customer
Address of Customer: [UK and/or
International]
Purpose of Exchange:
Proof of Purpose of Use, if Available Attached/ not attached
Customer Declaration
about Source of Funds:
Customer Signature
Description As appropriate
1. Photo ID [Passport/Driving Licence/EEA National ID Card] □
2. Proof of Address [EU Driving License/UK Utilities Bill/Bank □
Statement]
3. Payslips last 3 Months- [If Employee and/or Director] □
4. Bank Statement Last 3 Months- [Any Customer] □
5. Sale of Assets Receipts/Legal Documents □
6. Annual Accounts- [If Shareholder, Received dividend] □
7. Tax Return copy- [For self Employed/Sole Trader/Partnership □
8. Any others information as a source of fund:

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 Approved Not Approved.
If Approved/Not Approved, Explain
Why...............................................................................................................................................
........................
Approved By
Compliance Officer Name____________________________ Signature: __________________

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