AML Anti-Money Laundering Policies, Controls and Procedures

Name of firm: Forward North

May 2025

 

Introduction

The Money Laundering Regulations in force require supervised firms to “establish and maintain policies, controls and procedures to mitigate and manage effectively the risks of money laundering and terrorist financing identified in any risk assessment undertaken by the relevant person”.

Forward North is committed to adherence to the UK legislation enacted to combat money laundering and preventing criminals from being able to use this firm to help them launder money, or to finance terrorism. References to money laundering (ML), terrorist financing (TF), and proliferation financing (PF) in this document should be taken to mean ML/TF/PF.

 

Client due diligence and Enhanced due diligence

It is our policy to undertake client due diligence (CDD) and ensure that evidence of identity is obtained and retained as appropriate to that risk assessment for all clients. Enhanced due diligence (EDD) shall be performed where considered necessary. In practice, we obtain a client’s:

  • name

  • photograph on an official document which confirms their identity (passport/driving licence)

  • electronic ID

  • residential address and date of birth

The firm will document its CDD using using AAT’s client onboarding checklist.

All risks, including those not within a category, will be assessed in isolation and also when grouped together. These risks will be used to assess the customer due diligence process.

This evidence will be obtained before work for the client is commenced, and when periodic reviews are undertaken (if more evidence is required then, and when changes occur during the relationship with the client). In all cases where the evidence is not available, the matter will be referred to the Money Laundering Reporting Officer (MLRO).

The EDD measures when dealing with a politically exposed person (PEP) are making sure that only senior management approves a new business relationship; taking adequate measures to establish where the person’s wealth and the funds involved in the business relationship come from and carrying out stricter ongoing monitoring of the business relationship

Forward North is aware of the need to perform additional CDD/EDD monitoring measures, where appropriate, to prevent the use of products and transactions which might favour anonymity from being used to facilitate money laundering, terrorist financing, or proliferation financing. Further scrutiny will take place in any case where there are reasonable grounds, such as:

  • there is a high risk of ML/TF/PF or in any other case which by its nature can present a higher risk of ML/TF/PF

  • where either the client or other parties to the transaction or business relationship are established as being connected to a high-risk third country

  • where either the client or other parties to the transaction or business relationship are established as being subject to financial or trade sanctions

  • where the client or a beneficial owner of a client is a PEP, or a family member or known close associate of a PEP

  • in any case where a client has provided false or stolen identification documentation or information on establishing a business relationship

  • in any case where a transaction is complex or unusually large, or there is an unusual pattern of transactions which have no apparent economic or legal purpose.

  •  

In all cases where the evidence is not available, the matter will be referred to the Money Laundering Reporting Officer (MLRO).

 

Risk management

It is our policy to undertake a firm-wide risk assessment. The firm will assess the ML/TF/PF risks it faces and make proportionate responses to them. Risks are grouped into categories:

  • Client risk

  • Service risk

  • Geographic risk

  • Delivery channel risk

  • Industry risk

 

The firm will document this risk assessment using AAT’s firm-wide risk assessment template.

To focus resources on the areas of greatest risk, Forward North uses a risk-based approach. A risk assessment is conducted at least annually, but with new and changing risks considered as and when they are identified.

 

Ongoing monitoring

Client due diligence, periodic reviews and risk assessments are conducted on an ongoing basis and any additional information identified should be dealt with and further information obtained from clients where necessary. Forward North considers the following red flags when dealing with both new and existing clients and uses them as indicators for our ongoing monitoring and when to submit a suspicious activity report:

  • whether clients are overly secretive or evasive

  • if the amount or source of funds seems unusual

  • if there are odd discrepancies in client transactions or business activities

  • if client activities involve complex business structures that make it unclear who is conducting a transaction or purchase

  • the client has taken steps to hide their identity, or is the beneficial owner is difficult to identify

  • where information or documents being withheld by the client or their representative, or they appear to be falsified

  • high-risk geographical area

  • financial or trade sanctions.

The firm will document its ongoing monitoring using AAT’s Client monitoring review checklist and AML annual compliance review checklist.

 

Reporting

Suspicious activity reports

It is a requirement that where Forward North knows or suspects (or has reasonable grounds for knowing or suspecting) that a person is engaged in ML/TF/PF as a result of information received in the course of the business or otherwise through carrying on that business then they must comply with:

Part 3 of the Terrorism Act 2000;

Part 7 of the Proceeds of Crime Act 2002; and make a Suspicious Activity Report.

All staff must report every instance where they have knowledge or suspicion of ML/TF/PF to the MLRO as soon as reasonably practical. This should be done by using the Internal Money Laundering Report form available thorugh TaxDome.

It is our policy to report all suspicions identified to the National Crime Agency (NCA) where required using the SAR online reporting service.

Breaches of financial sanctions

It is a requirement that where Forward North knows or suspects (or has reasonable grounds for knowing or suspecting) that a person is a designated person or has breached a financial sanction, they must inform OFSI as soon as practicable.

All staff must report every instance where they have knowledge or suspicion that a person is a designated person or has breached a financial sanction to the MLRO as soon as reasonably practical. This should be done by using the Internal Money Laundering Report form available through TaxDome.

It is our policy to report all suspicions identified to OFSI where required using the OFSI Compliance reporting form.

Information about the approach OFSI takes to financial sanctions can be found here.

Discrepancies in people with significant control (PSC) register

It is a requirement that where Forward North identifies a reportable discrepancy between the information they hold about a PSC and information held on the PSC register, they must tell Companies House as soon as practicable.

All staff must report every instance where they identify a discrepancy between the information the firm holds about a PSC and information held on the PSC register to the MLRO as soon as reasonably practical. This should be done by using the Internal Money Laundering Report form available through TaxDome.

It is our policy to tell Companies House about reportable discrepancies where required using Companies House online service.

Information about the types of discrepancies that must be reported and the definition of a PSC can be found here.

 

Record keeping

It is our policy to maintain records of client identification and considerations of money laundering issues securely, for the entire period that we act for the client and for five years after we cease to act in accordance with the regulations.

If we are required to retain them under statutory obligation, or to retain them for legal proceedings, or by client consent, the records will be retained for not more than 10 years after we cease to act.

Clients are made aware of the data that will be collected about them, why the data is being collected and record retention through the engagement letter in place between the firm and that client and/or our privacy notice. 

 

Internal controls

This practice is owned by and run by one principal who controls all aspects of the work undertaken. There are no staff members or sub-contractors and therefore no one else who I need to communicate with in relation to control of AML risk.

 

Compliance review

It is our policy to undertake a regular compliance review to ensure that the requirements of the regulations are being followed. A record of the review and actions identified is documented and maintained on file.

 

Staff training and awareness

I am aware of the requirements of the MLR and will undertake regular training to recognise and deal with transactions that may be related to ML/TF, as well as to identify and report anything that gives grounds for suspicion. I shall retain a written record of the training delivered is maintained.