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Anti-Money Laundering Policy

Introduction

C&S Bookkeeping is committed to Anti-Money Laundering regulations and assessing the risks that could be used for money laundering, including terrorist financing. The firm has a policy of zero tolerance to any involvement in money laundering, including bribery and the criminal facilitation of tax evasion when dealing with the firm’s own or our client’s affairs.

Name and contact details of the Nominated Officer:

Name: Catherine Thompson
Email Address: admin@candsbookkeeping.co.uk
Postal Address: 34 Wenhill Height, Calne, Wiltshire, SN11 0JZ

How will Risk be Assessed

C&S Bookkeeping uses a risk-based approach to prevent money laundering. This involve completing the risk assessment for each client and gaining knowledge on their business before any engagement is agreed upon.
We will consider whether our clients and their stakeholders have characteristics associated with money laundering, financial crime and terrorist financing. In doing so we will ensure we have able to answer the questions listed below:

C&S Bookkeeping will always ensure that we understand where the client’s income is coming from and that it is not linked to Money Laundering or funding Terrorist Activity.

Geographic Risk

C&S Bookkeeping will be wary of working with any companies based in non-EU countries and has read The Money Laundering and Terrorist Financing (Amendment) (No. 3) (Hight-Risk Countries) Regulations 2021. We will carry out enhanced client due diligence if any future clients are linked with the counties listed in these regulations as specified.

What is Client Due Diligence

C&S Bookkeeping will carry our client due diligence on ALL clients – even those that we have known them for many years. It will also be repeated every two years.
Every client will be asked to provide government issued documents such as a passport or driving license along with utility bill, bank statement and other official documents. Copies of these documents will be taken and kept securely.
We may also check the Fraud List, Land Register and Electronic ID Services.
When C&S Bookkeeping establishes a new business relationship we will obtain information on:

What will happen if there is a risk?

If CDD fails at any point C&S Bookkeeping will no longer carry out bookkeeping for that client and ALL suspicious activity will be provided in a Suspicious Activity Report (SAR) to the National Crime Agency. Home - National Crime Agency

Risk Assessment – Data Protection

In accordance with our obligations under anti-money laundering legislation your personal identity data gained through CDD will be processed solely for the purpose of preventing money laundering or terrorist financing and as you otherwise agree, for example, in order for us to provide the services for which you engage us.
All CDD data will be kept electronically for 5 years from the end of the business relationship. All personal information will be kept securely.
Reports to the National Crime Agency (NCA) will also be retained for at least five years.
C&S Bookkeeping will never pass on any clients details to any third party.

See our Privacy Policy for more details on data protection.


April 2022