Money Laundering Policy

All clients must be identified fully with two forms of ID, evidence of identity being photographic and also evidence of residence e.g. a utility bill dated in the last three months.

For customers other than private individuals

For customers who are not private individuals, such as corporate customers and private companies, the business must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company.

Suspicious Activity Reporting (SAR)

If Blue Sky thinks that a person is or has been engaged in money laundering or terrorist financing a SAR report will be completed and forwarded to the Serious Organised Crime Agency (SOCA).

What is Suspicious Activity?

This list is by no means exhaustive.

New Customers:

• Reluctance to provide details of their identity
• Customer is trying to use intermediaries to hide their identity or involvement
• There appears to be no genuine reason for the customer using the business’s services

Regular/Existing Customers:

• The transaction is different from the normal business of the customer
• Size or frequency of the transaction is not consistent with the normal activities of the customer
• There has been a significant or unexpected improvement in the customer’s financial position particularly where they are unable to give a proper explanation of where the money came from.

Transactions:

• Money is paid by a third party who does not appear to be connected with the customer
• The customer requests payment to a third party who has no apparent connection with the customer
• A cash transaction is unusually large and the customer will not disclose the source of funds.
• A transaction is carried out for less than market value with an unconnected person

Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential

Record Keeping

The following records are required to be kept for 5 years:

• Copies of the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed.
• Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed.

The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.