Home » AMCI ANTI MONEY LAUNDERING POLICY STATEMENT

AMCI ANTI MONEY LAUNDERING POLICY STATEMENT

 

AMCI ASSOCIATES LTD

AML Policy and Procedures Document

Version 3

Created/Updated in December 2025

Approved by the MLRO: 

Ihqlak Hussain

 

 

Money Laundering Reporting Officer (MLRO)

The money laundering reporting officer (MLRO) is Ihqlak Hussain. 

Mr Hussain can be contacted on 01213278316 and his email is:  ihqlak@amci-associates.co.uk

The alternative MLRO within the firm is Nazia Allen.

Mrs Allen can be contacted on 01213278316 and her email is:  nazia@amci-associates.co.uk

List of responsibilities

The MLRO responsibilities include, but not limited to, the following;

  • have oversight of, and be involved in, MLTF risk assessments;
  • take reasonable steps to access any relevant information about the business;
  • obtain and use national and international findings to inform their performance of their role;
  • create and maintain the business’s risk-based approach to preventing MLTF;
  • support and coordinate management’s focus on MLTF risks in each individual business area. This involves developing and implementing systems, controls, policies and procedures that are appropriate to each business area;
  • take reasonable steps to ensure the creation and maintenance of MLTF documentation;
  • develop Customer Due Diligence (CDD) policies and procedures;
  • ensure the creation of the systems and controls needed to enable staff to make internal SARs in compliance with POCA [Proceeds of Crime Act 2002];
  • receive internal SARs and make external SARs to the NCA;
  • take remedial action where controls are ineffective;
  • draw attention to the areas in which systems and controls are effective and where improvements could be made;
  • take reasonable steps to establish and maintain adequate arrangements for awareness and training;
  • receive the findings of relevant audits and compliance reviews (both internal and external) and communicate these to the board (or equivalent managing body).
  • report to the board (or equivalent managing body) at least annually, providing an assessment of the operations and effectiveness of the business’s AML systems and controls. This should take the form of a written report. These written reports should be supplemented with regular ad hoc meetings or comprehensive management information to keep senior management engaged with AML compliance and up to date with relevant national and international developments in AML, including new areas of risk and regulatory practice. The board (or equivalent managing body) should be able to demonstrate that it has considered the reports and ad hoc briefings provided by the MLRO and then take appropriate action to remedy any AML deficiencies highlighted.

MLRO Report

The MLRO shall conduct and document a report testing the firm’s AML systems and controls on annual basis. 

Firm-wide risk assessment

 

Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), it is a legal requirement for every accountancy firm to conduct, document and keep up to date a firm-wide risk assessment.  Before under taking firm-wide risk assessment and proliferation financing risk assessment on periodic basis, the MLRO reviews the MLR 2017, MLR (Amendment) 2019 and CCAB’s Anti-Money Laundering Guidance For The Accountancy Sector (AMLGAS). Furthermore, the MLRO reviews the HM Treasury national risk assessment, Financial Action Task Force (FATF) Guidance on the Risk-Based Approach for Accountants and the National Crime Agency’s website. The MLRO keeps up to date by reading relevant materials to help assess the risks associated with the firm.

Whilst conducing firm-wide risk assessment and proliferation financing risk assessment, the MLRO considers the risks presented by:

  • its clients
    • the countries or geographic areas in which it operates
    • its products or services
    • its transactions
    • its delivery channels.

Suspicious Activity Reporting (SAR)

All employees must report their knowledge or suspicions of MLTF to the MLRO. The MLRO will consider the internal report and if the MLRO also suspects MLTF, then the MLRO will submit an external SAR to the NCA. Should the MLRO decide not to submit an external SAR, they will document their reasoning.

Internal SARs

Employees must complete the internal SAR form. This must be shared with the MLRO as soon as possible.

Consequence of failure to report

As per s330 of the Proceeds of Crime Act 2002, a person commits an offence if, during the course of business they develop knowledge or suspicion (or have reasonable grounds for doing so) that another person is engaged in money laundering, and they do not make the required disclosure as soon as is practicable. Note that an offence is committed regardless of whether it subsequently transpires that the money laundering cannot be proven, or that it did not occur.

The required disclosure is a disclosure of the information or other matter to the MLRO or the NCA.

Tipping-off

As per s333 of the Proceeds of Crime Act 2002, a person commits an offence if they know or suspect that a disclosure has been made, and they make a disclosure which is likely to prejudice any investigation which might be conducted following the disclosure.

In addition to this (as per s342), a person commits an offence if they know or suspect that an appropriate officer is conducting or about to conduct a confiscation investigation, a civil recovery investigation, a detained cash investigation or a money laundering investigation and either makes a disclosure which is likely to prejudice it or falsifies, conceals, destroys or otherwise disposes of relevant document or causes another to do so.

Training

The MLRO is responsible for ensuring that all relevant employees undertake the AML training at the appropriate time.

All training will be conducted internally/externally on an annual basis.

The AML training covers the following topics: AML red flags, explaining the law and regulations, conducting customer due diligence (CDD), SARs and how to deal with suspicious transactions, case studies with examples of ML methods, tipping off and any other relevant matters.

A log showing the training that was given, the dates on which it was given, which individuals received the training and the result from any assessments is maintained. The training log can be found by contacting the MLRO.

Client Risk Assessment

A client risk assessment is completed using the internal client risk assessment form during onboarding, and annually ongoing monitoring. Clients are categorised as either low, medium or high risk. Below is the criteria for each risk rating.

High-Risk Client

Any client who has one or more of the following risk factors will be considered as high risk:

  • The business relationship is conducted in unusual circumstances
  • The client is a resident or transacts with a geographical area of high risk
  • Cash-intensive businesses (eg takeaways, retail shops, scrap metal dealers, car wash, nail-bars, massage parlours)
  • The corporate structure of the customer is unusual or excessively complex given the nature of the company’s business
  • High-net-worth individual (eg any individuals/entities with assets of over £5m)
  • Politically exposed person (PEP)
  • High-value businesses (eg jewellers, car dealerships, art, antiques etc)
  • The type of industry/business of the firm is at high risk of MLTF eg properties (selling and renting), import and export (including haulage, freights, and shipping), money service bureaus, cryptocurrency, visa and immigration services, investment services, precious metals (eg gold, diamond trading), charities etc.

 

Low-Risk Client

Any client who is a public administration, a publicly owned enterprise or a company whose securities are listed on a regulated market will be considered as low risk.

Medium-Risk Client

Any client who does not have any high- or low-risk factors will be classified as medium risk.

Due Diligence Policy

We conduct due diligence during the onboarding for all new clients.  Identification documents and proof of home address are obtained and kept as hard copies on client files.  For existing clients, records are updated on an ongoing basis.  Overall responsibility lies with the MLRO.  However, all colleagues responsible for onboarding are appropriately trained to ensure that risks are minimised.  KYC checklists are to be completed and independent checks shall be conducted to verify the information such as The Companies House, Google, UK – UN sanctions screening etc.

CDD is conducted on all clients.  Typically, identification documents such as passport, driving Licence and any other verifiable document of good quality are obtained and kept on the client file.  Also, recent proof of home address (eg, less than 3 months old) in the form utility bill, bank statement etc are obtained and copies kept.  Wherever possible, original documents are examined and copies made for the file.

For high risk clients, enhanced due diligence is carried out.  This typically involves checking source of wealth and/or source of funds.  This is done by obtaining bank statements, and any relevant annual accounts prepared in the past six months.  Social media searches are also conducted to verify data/information.

Ongoing Monitoring Policy

The firm will review any client who is classified as high risk every six months. All medium- and low-risk clients will be reviewed every 12 months. The review will ensure all due diligence information is still relevant and up to date. This includes:

  • checking identification and address is still valid; if not, this will be updated
  • checking there are no discrepancies on the person of significant control register
  • checking annual turnover is in line with what we would expect.

Events prompting an immediate review include:

  • a change in the client’s identity
  • a change in beneficial ownership of the client
  • a change in the service provided to the client
  • information that is inconsistent with the business’s knowledge of the client.

Sanctions Screening

As a business, we must comply with any sanctions, embargos or restrictions in respect of any person, entity or jurisdiction to which the UN or UK has decided to apply such measures.  During client onboarding process and thereafter annually, checks must be undertaken and documented through know your customer (KYC) process.

Control Assurance

As part of firm-wide risk assessment, we have a continues process of undertaking regular reviews to understand the adequacy and effectiveness of the MLTF systems and any weaknesses identified are rectified.  

Record-Keeping Policy

The maintenance and retention of records for five years after ceasing to act for a client relating to:

  • clients risk assessments
  • client identity and verification
  • clients ongoing monitoring
  • staff training
  • internal reporting
  • external reporting

 

Version Control

Date

Version

Amendment/Review

Person responsible

01/10/2018

V 1.0

Document created

Ihqlak Hussain

31.03.2025

V 2.0

Annual review. No 2 amendments made. AML P&P reviewed – significant changes made following ACCA guidance after ACCA desk review in August 2025. Next review to take place by 31/03/2026.

Ihqlak Hussain

31.12.2025

V 3.0

No amendments necessary at this stage.  However, changes expected in light of regulatory supervision changes coming in the foreseeable future.

Ihqlak Hussain