Anti-Money Laundering (AML) Policy

1) Introduction

This policy sets out the approach of Charles Henry Peppiatt to prevent money laundering and terrorist financing in accordance with:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000

Charles Henry Peppiatt Limited is registered and supervised by HM Revenue & Customs for compliance with the Money Laundering Regulations 2017.

2) Policy Statement

We are committed to preventing our business from being used to facilitate money laundering. We will take all reasonable steps to ensure compliance with AML laws and regulations.

3) Responsibilities

• The Money Laundering Reporting Officer (MLRO) is Ben Felfeli, responsible for implementing and overseeing this policy.
• All staff must report suspicious activity to the MLRO immediately.

4) Customer Due Diligence (CDD)

We must verify the identity of clients before entering into a business relationship or transaction:

• Individual clients: Obtain and verify photographic ID (passport/driver’s licence) and proof of address (utility bill/bank statement, no older than 3 months).
• Corporate clients: Verify company details via Companies House, and identify beneficial owners (25%+ ownership).

Enhanced Due Diligence (EDD) is required if the client is:

• Not physically present
• A politically exposed person (PEP)
• From a high-risk third country (as identified by the UK government)

5) Ongoing Monitoring

We will continually monitor transactions to ensure they are consistent with our knowledge of the client. Any unusual or suspicious activity will be reported to the MLRO.

6) Record Keeping

We will keep CDD and transaction records for five years after the business relationship ends.

7) Training

All employees will receive regular AML training to ensure they understand their responsibilities and how to detect and report suspicious activity.

8) Suspicious Activity Reporting (SAR)

Suspicious transactions or activities must be reported to the MLRO. The MLRO will determine whether a report should be submitted to the National Crime Agency (NCA) using a Suspicious Activity Report.

9) Review of Policy

This policy will be reviewed annually or when legislation changes, whichever comes first.