Anti-money laundering policy

Introduction

LmC is committed to the highest standards of anti-money laundering (AML) compliance and the prevention of terrorist financing. This policy outlines our approach to identifying, mitigating, and reporting risks related to money laundering and terrorist financing activities.

Objectives

To comply with all relevant AML laws and regulations.
To establish robust internal controls for the detection and prevention of money laundering and terrorist financing.
To train employees on AML responsibilities and ensure compliance with our AML policy.
To protect the integrity and reputation of Log my Care.

Scope

This policy applies to all employees, officers, directors, and agents of LmC. It covers all activities conducted by LmC and its subsidiaries.

Regulatory Framework

This policy is designed to comply with the following key legislation and regulations:

Proceeds of Crime Act 2002 (POCA)
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017)
Terrorism Act 2000
Criminal Finances Act 2017

Roles and Responsibilities

Board of Directors: Overall responsibility for AML compliance.
AML Compliance Officer: Responsible for the implementation and maintenance of this AML policy, reporting to the Board, and acting as the primary point of contact for AML issues.
Employees: Responsible for complying with the AML policy and reporting any suspicious activities to the AML Compliance Officer.

Log my Care Commitments

Customer Due Diligence (CDD)

Identification and Verification: Before establishing a business relationship, we will identify and verify the identity of our customers and beneficial owners.
Ongoing Monitoring: Continuously monitor customer transactions to identify and report suspicious activities.

Reporting Suspicious Activities

Employees must report any knowledge or suspicion of money laundering or terrorist financing to the AML Compliance Officer.
The AML Compliance Officer will file Suspicious Activity Reports (SARs) with the National Crime Agency (NCA) as required by law.

Record-Keeping

Maintain records of customer identification, transaction details, and any suspicious activity reports for a minimum of five years.
Ensure records are kept securely and are readily accessible for review by regulatory authorities.

Training and Awareness

Provide regular AML guidance and / or training to all employees to ensure they understand their responsibilities and can identify and report suspicious activities.
Guidance / training will cover relevant AML laws, internal policies, and procedures, and the recognition and handling of suspicious activities.

Risk Assessment

Adopt a risk-based approach to AML compliance, assessing the risk profile of customers, products, and services.
Apply appropriate measures to mitigate identified risks, including enhanced due diligence for higher-risk scenarios.

Sanctions Compliance

Screen customers and transactions against relevant sanctions lists.
Ensure compliance with international sanctions regimes and refrain from engaging in prohibited activities or transactions.

Policy Review

This policy will be reviewed annually or more frequently if required by changes in legislation or business operations.
Any amendments to the policy will be approved by the Board of Directors.

Reporting and Escalation

Employees must promptly report any breach or suspected breach of this policy to the AML Compliance Officer.
Significant breaches will be escalated to the Board of Directors.

Conclusion

LmC is committed to maintaining a robust AML compliance program to protect our business and community from the risks associated with money laundering and terrorist financing. Adherence to this policy is mandatory for all employees, and any failure to comply may result in disciplinary action.

Questions

Please contact Umar Aziz (AML Compliance Officer).

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