BACKGROUND:

Money laundering is the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source.

Contour Architectural Designs Limited, a limited company registered in England under 09873015 (the "Company" / "Our" / "We" / "Us"), whose registered address is Building 46, 9 Marlborough Road, Royal Arsenal, London, SE18 6TA and whose main trading address is 70 High Street, Canvey Island, Essex, SS8 8LX has taken the decision to embrace the underlying principles behind the money laundering legislation and regulations and put in place anti money laundering policies, procedures and reporting arrangements appropriate and proportionate to Our activities

1. Scope - What Does This Policy Cover?

The principal Legislation and Regulations relating to money laundering are the Terrorism Act 2000, Proceeds of Crime Act 2002 and the Money Laundering Regulations 2007. A notable aspect of this legislation was that the burden for identifying acts of money laundering was significantly shifted from Police and Government agencies to organisations and their employees. This Policy therefore covers the Company and any of Our employees.

2. What is Money Laundering?

2.1 Money laundering is where money obtained, as a result of a crime, is used to pay for services or goods. Although the term 'money laundering' is usually associated with organised criminal activities, it can include a suspicion that someone you know, or know of, is benefiting financially from dishonest activities, e.g. non-payment of income tax.

2.2 People involved in handling criminal property look for ways to secure and safeguard the proceeds of their criminal activities. Although other ways exist, cash is the mainstay of criminal transactions, being the most reliable and flexible, and having little or no audit trail.

2.3 Criminals often transport cash out of the UK using couriers, usually through airports, to pay into banks overseas. They use this money to purchase property abroad, or to pay to their families.

2.4 In the UK, the most popular method of money laundering is thought to be the purchase and/or refurbishment of property, followed by investment in front companies, or high cash turnover businesses (often legitimate businesses), or by funding a lifestyle. After property, the most significant assets bought by criminals are jewellery, artwork, antiques, cars and boats.

2.5 Criminals invest cash in financial products with a view to selling them quickly (if necessary at a loss). Criminals also use trusts to launder money because of their secretive nature and flexibility, often using front companies to hide identities. Gambling large amounts at relatively low odds is also used, since winnings are usually received in the form of cheque payments.

2.6 Criminals use 'layering' to confuse the audit trail. This involves passing transactions through several stages, often eventually banking the proceeds of business income and transferring the money overseas to a country whose regulatory regime is weaker.

2.7 Examples of money laundering can include:

  • large cash payments
  • asking for cash refunds on credit card or bank payments
  • asking for refunds directly to a bank account that differs from the one that paid the invoice, or asking for an invoice paid in cash to be returned to a bank account
  • overpaying invoices for our services, then asking for refunds in a different method i.e. overpayment in cash, refund to bank or vice versa
  • paying invoices from a bank account that is not held in the customer's name

2.8 Appendix A details examples of possible situations involving exposure to money laundering and the proceeds of crime. Appendix B lists the current Money Laundering legislation.

3. What are the Main Money Laundering Offences?

3.1 There are three main offences:

  • Concealing: knowing or suspecting a case of money laundering, but concealing or disguising its existence.
  • Arranging: becoming involved in an arrangement to launder money, or assisting in money laundering.
  • Acquisition, use or possession: benefiting from money laundering by acquiring, using or possessing the property concerned.

3.2 There is also a 'third party' offence - failure to disclose one of the three main offences detailed above.

3.3 None of these offences are committed if:

  • the persons involved did not know or suspect that they were dealing with the proceeds of crime; or
  • a report of the suspicious activity is made promptly to the Money Laundering Reporting Officer (the "MLRO").

4. What are the Penalties?

4.1 Money laundering offences may be tried at a magistrate's court or in the Crown Court, depending on the severity of the suspected offence. Trials at a magistrate's court can attract fines of up to £5,000, up to 6 months in prison, or both.

4.2 In a Crown Court, fines are unlimited and with possible prison sentences of between two to 14 years.

5. What is the Company's Policy on Monday Laundering?

5.1 All organisations, including the Company, must report any money laundering suspicions for cash transactions over £9,000 or equivalent. To help prevent money laundering, the Company has set a cash payment limit of £8,000. No cash payments above £8,000 will be accepted for any of the Company's services under any circumstances.

5.2 Where amounts are paid in cash below the £8,000, the Company requires that the Customer to provide proof of identity and proof of residence in accordance with Know Your Client regulations. These must be from two separate sources. Acceptable documents for identity are either a passport or driving licence, and acceptable documents for proof of residence are either a driving licence (if not used as proof of identity), a utility bill, a council tax bill, a letter from a government agency or alternatively a bank statement (the financial details of which can, of course, be obscured).

5.3 This is not designed to prevent customers making payments for Our services but to minimise the risk to Us of high value cash transactions.

5.4 Our policy is to:

  • prevent, where possible, the Company and Our employees from being exposed to money laundering.
  • identify the potential areas where money laundering may occur and provide staff with guidance and training to help prevent money laundering.
  • report all suspicions to the Company's nominated Money Laundering Reporting Officer - who is Alexander Cope-Norris.
  • use the Proceeds of Crime Act to recover any monies lost to money laundering.

6. Roles and Responsibilities

Responsibility for identifying acts of money laundering is moving away from government agencies and more towards organisations and their employees. The Company has assigned the following responsibilities for anti-money laundering measures within its operations.

It is each employee's responsibility to remain vigilant and report any suspicions to help us prevent and detect money laundering. Failure to report a suspicion of money laundering may lead to disciplinary action. Furthermore, Solicitors and Accountants have a professional duty to report any suspicions of money laundering.

7. Reporting

The MLRO will review all reported money laundering allegations and decide whether the transaction / circumstances are suspicious. The MLRO will report suspicions to the National Criminal Intelligence Service (NCIS) and the Police, as appropriate.

8. What should I do if I suspect a case of money laundering?

If you suspect a case of money laundering:

  • Do not tell the customer about your suspicions.
  • Report your suspicions immediately to the Company's Money Laundering Reporting Officer.
  • Keep all records relating to the transaction(s). If you are unsure about what records or information to keep, please ask the MLRO.

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