Anti-Money Laundering

1. Introduction

CASEwork Services CIC Ltd is an accountancy service provider regulated by HMRC for anti-money laundering (AML) supervision.

We are committed to preventing money laundering and terrorist financing and complying with all applicable legislation, including:

• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000
• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017)

This policy sets out the controls and procedures we use to mitigate AML risks.

2. Scope

This policy applies to all employees, contractors and anyone acting on behalf of CASEwork.

It applies to all regulated services including:

• Bookkeeping and financial transactions services
• Management accounting
• Payroll services
• Financial administration

3. Firm-Wide Risk Assessment

CASEwork maintains a documented assessment of the risks of money laundering and terrorist financing relevant to its business.

This assessment considers:

• Types of services provided
• Client types (e.g. charities, companies)
• Delivery channels (e.g. remote service delivery)
• Geographic risk

The risk assessment is reviewed annually and updated where necessary.

4. Risk-Based Approach

CASEwork applies a risk-based approach to AML compliance.

Each client is assessed for risk based on factors including:

• Nature of the organisation and activities
• Source of funds
• Complexity of structure
• Geographic exposure

Clients are categorised as low, standard or high risk.

Enhanced due diligence (EDD) is applied where higher risks are identified.

5. Roles and Responsibilities

Money Laundering Reporting Officer (MLRO)

The MLRO is responsible for:

• Maintaining AML policies and procedures
• Receiving and assessing internal suspicious activity reports
• Submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA)
• Maintaining the firm-wide risk assessment
• Ensuring staff training
• Acting as the main point of contact with HMRC

Employees and Contractors

All staff must:

• Follow this policy
• Complete AML training
• Report suspicions promptly to the MLRO

6. Customer Due Diligence (CDD)

CDD must be completed:

• Before establishing a business relationship
• When there is suspicion of money laundering
• When client circumstances change
• When previously obtained information is unreliable

Standard Due Diligence

For individuals:

• Name, address, date of birth
• Verification using reliable documentation

For organisations:

• Organisation name and registration details
• Identification of directors, trustees and beneficial owners

Beneficial Ownership

We identify individuals who ultimately own or control the organisation, including persons with significant control.

Enhanced Due Diligence (EDD)

EDD is applied where higher risk is identified and may include:

• Source of funds verification
• Additional identity checks
• Senior management approval

7. Politically Exposed Persons (PEPs) and Sanctions

CASEwork will assess whether clients or beneficial owners are Politically Exposed Persons (PEPs) or subject to sanctions.

Where identified, enhanced due diligence and senior approval will be required.

8. Ongoing Monitoring

Client relationships are monitored on an ongoing basis to ensure consistency with our knowledge of the client.

CDD information is reviewed periodically and updated where necessary.

9. Reporting Suspicious Activity

All staff must report suspicions to the MLRO immediately.

The MLRO will determine whether a SAR should be submitted to the NCA.

Staff must not disclose suspicions to clients (tipping off).

10. Record Keeping

We maintain records of:

• Client identification and verification
• Risk assessments
• Transactions and services provided
• SARs and related documentation

Records are retained for at least five years after the end of the business relationship.

11. Training

All staff receive:

• AML training on induction
• Regular refresher training

Training ensures staff can recognise and report suspicious activity.

12. Data Protection

Personal data is handled in accordance with UK GDPR and the Data Protection Act 2018.

13. Independent Review

The effectiveness of AML controls is reviewed periodically by a person independent of day-to-day AML processes or by an external adviser.

14. Non-Compliance

Failure to comply with this policy may result in disciplinary action and could expose individuals and the firm to legal penalties.

15. Review

This policy will be reviewed annually and updated as required to reflect changes in legislation or business activities.