Anti-Money Laundering and Counter-Terrorist Financing Policy Statement

Introduction 

This policy sets out FLAS Financial Services' commitment to understanding and minimising our risks in relation to money laundering and terrorist financing, ensuring our services are not abused to legitimize the proceeds of crime. Our commitment to this strengthens our goals of achieving good ethical business and trading standards. 

Objective 

Our aim, by having robust policies and procedures and creating a compliance culture within the firm, is to prevent money laundering and terrorist financing. To achieve this, we have undertaken the following measures: 

Appointment of the Nominated Officer 

The nominated officer’s role is to be aware of any suspicious activity in the business that might be linked to money laundering or terrorist financing and, if necessary, to report it. They are responsible for: 

• Receiving reports of suspicious activity. 

• Evaluating whether there is evidence of money laundering or terrorist financing. 

• Reporting any suspicious activity or transaction to the National Crime Agency (NCA) by completing and submitting a Suspicious Activity Report (SAR). 

Nominated Officer Details 

• Name: Batsirai Muka 

• Telephone Number: 07958204458

• Email Address: batsi@flasinc.co.uk 

The nominated officer is also available to discuss any matters relating to the firm’s policies and procedures regarding the Money Laundering Regulations (MLR) in force and helping you understand your obligations. In the absence or sickness of the nominated officer, no deputy officer is required as this is a sole trading firm. 

Internal Procedures to Prevent Money Laundering and Terrorist Financing 

We have established appropriate and risk-sensitive policies and procedures relating to: 

• Customer due diligence (CDD) 

• Reporting 

• Recordkeeping 

• Internal control 

• Risk assessment and management 

• Compliance management 

• Communication 

Internal Training Requirements 

We ensure that: 

• Individuals within the firm understand their responsibilities within the firm’s policy and procedures and their wider responsibilities under the UK’s anti-money laundering strategy. 

• Regular training is provided on: 

• Awareness of relevant legislation and any changes. 

• Understanding roles and responsibilities under the anti-money laundering regime. 

• Recognising potential suspicious activity. 

• Reporting suspicious activity. 

• The firm’s exposure to risk. 

• The firm’s client due diligence policies and procedures. 

Record Retention 

We will retain the following records for five years after ceasing to act for a client: 

• Client’s risk assessments 

• Client’s identity and verification 

• Client’s ongoing monitoring 

• Staff training 

• Internal and external reporting 

Reporting Suspicions 

The firm, through the nominated officer, has established procedures for: 

• Assessing internal SARs and the decision-making process for external reporting. 

• Making SARs to the NCA and secure retention and storage of internal and external reports. 

• Reporting any knowledge or suspicion of financial sanctions breaches to the Office of Financial Sanctions Implementation (OFSI). 

Aiding Law Enforcement 

The firm, through the nominated officer, has established procedures for aiding any law enforcement agencies who obtain money laundering investigation orders against our clients. These procedures relate to the collation and secure retention of the information required and systems to ensure the confidentiality of the client is maintained where necessary. 

Staff and Subcontractor Commitment to the Firm’s Policy and Procedures 

It is important that any potential staff or subcontractors understand the compliance culture and the roles and responsibilities placed upon them. Penalties, including fines and imprisonment, can apply to individuals as well as the firm. Therefore, we must: 

• Ensure we understand the firm’s policy and procedures contained in this document, and ask the nominated officer if unsure. 

• Ensure regular training on recognizing and dealing with transactions and other activities related to money laundering or terrorist financing. 

• Follow procedures to discuss any questionable situation or make an internal SAR. 

• Avoid speculating whether a crime has been committed; reasonable suspicion is required. 

• Remember that we are not investigators; that is the role of law enforcement. 

• Avoid tipping off clients as it is an offence under the legislation. 

Policy Review 

Date of Review: 31 October 2024

Reviewed By: Batsirai Mhuka

Role in Firm: Proprietor

Date of next review: 31 October 2025