PMW Management Wales Ltd (“the Firm”) is fully committed to adhering to all applicable anti-money laundering (AML) and counter-terrorist financing regulations. The purpose of this policy is to provide transparency to our clients and outline the procedures we implement to ensure compliance with UK law, including the Proceeds of Crime Act 2002, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and other applicable legislation.
This policy is intended to ensure the Firm’s services are not used for unlawful purposes and to maintain the highest levels of integrity in all client relationships.
Money Laundering Reporting Officer (MLRO)
Our compliance framework is overseen by a dedicated Money Laundering Reporting Officer (MLRO), who ensures all policies are implemented effectively and in compliance with relevant laws.
- Primary MLRO: John Moore
If you have any questions regarding our AML policies or compliance measures, please feel free to contact us.
Customer Due Diligence (CDD)
Customer Due Diligence (CDD) is a key part of our AML procedures. This process involves verifying the identity of our clients, understanding the purpose of the business relationship, and assessing associated risks.
We are required to perform CDD:
- At the start of every business relationship;
- If there are unusual or suspicious activities during the relationship;
- If changes occur in the client’s circumstances; or
- If doubts arise regarding previously obtained information.
Client Identification and Verification
For all clients, we use SmartSearch, an electronic verification platform, to streamline the identification and verification process. This allows us to securely cross-check identity documents, such as passports or driving licences, and validate information against global watchlists and databases to ensure compliance.
For UK-based clients, we require government-issued photo identification and proof of address. For non-UK clients, additional checks such as certified ID copies and enhanced electronic verification through SmartSearch may be conducted.
Risk Assessment
Each client is assessed for risk based on factors such as country of origin, the type of service requested, and the nature of transactions. High-risk clients or transactions (e.g., those involving Politically Exposed Persons or high-risk jurisdictions) may require Enhanced Due Diligence (EDD), which involves additional verification and ongoing monitoring.
Ongoing Monitoring
We continuously monitor client transactions to ensure they align with the expected nature of the business relationship. Unusual patterns or irregularities are flagged and reviewed to determine whether further action is needed.
Record Keeping
To comply with AML regulations, we retain the following records for at least five years after the end of a client relationship:
- Client Identification Records: Copies of ID documents and verification results (including electronic verification via SmartSearch).
- Transaction Records: Details of all payments, invoices, and transaction-related correspondence.
All personal data collected for AML purposes is handled in accordance with the Data Protection Act 2018 and UK GDPR. This information is used solely for compliance purposes and is securely stored with restricted access.
Reporting Suspicious Activity
We are legally obligated to report any suspicious activity or transactions to the National Crime Agency (NCA). Examples of suspicious activity include:
- Unusual or unexplained payments;
- Reluctance to provide identification or required information;
- Transactions involving high-risk jurisdictions; or
- Complex corporate structures lacking transparency.
If suspicious activity is identified, we will investigate and, if necessary, submit a Suspicious Activity Report (SAR).
Politically Exposed Persons (PEPs)
Before entering into a business relationship with a Politically Exposed Person (PEP), we apply Enhanced Due Diligence (EDD), which includes verifying the source of funds and wealth, as well as ongoing monitoring. Approval from the MLRO is required for any such relationship.
International Transactions and High-Risk Jurisdictions
Transactions involving clients or funds from high-risk jurisdictions are subject to strict scrutiny. Enhanced Due Diligence is required, and we follow all applicable guidelines from the Financial Conduct Authority (FCA) to ensure compliance.
Commitment to Compliance
PMW Management Wales Ltd is committed to maintaining compliance with all AML regulations. We continually review and update our policies to reflect changes in legislation and ensure the integrity of our services.
For more information or to raise a concern regarding our AML policies, please contact us.
This document is publicly available to demonstrate our dedication to preventing money laundering and terrorist financing, and to ensure transparency in our operations.