Money Laundering Policy

Money laundering has three main stages;

  1. Placement– This is the movement of cash from its source into another institute or entity.
  2. Layering – this is where the process is more complicated, the cash is converted into other monetary instruments.
  3. Integration/extraction – false entities are set up to appear legitimate for secret transaction or to lend back.

Carrying out customer due diligence requirements

We are obliged to carry out customer due diligence by taking the necessary steps to identify our customers. This means obtaining a customer’s:

  • name
  • official photograph document to confirms their identity
  • their residential address and date of birth

we require a government issued document i.e a passport, utility bills, bank statements or any other official documents. Other sources could be electoral registers and information from credit reference agencies such as Experian, Equifax and any other to identify the person.

Applying customer due diligence measures

We are obliged to carry customer due diligence checks as listed on gov.uk website:

  • when you establish a business relationship with a customer (or another party in a property sale)
  • when you suspect money laundering or terrorist financing
  • when you have doubts about a customer’s identification information that you obtained previously