Anti-Money Laundering (AML) Policy (UK) by Study Academy

Anti-Money Laundering (AML) Policy (UK, 2025 Edition)

Purpose

This Policy sets out the organisation’s framework for preventing its products, services or business operations from being used to facilitate money laundering, terrorist financing or other financial crime.

It is intended to ensure compliance with UK anti-money laundering and counter-terrorist financing legislation and to promote a culture of financial crime risk awareness.

Scope

This Policy applies to all staff, including senior management, and to all business units involved in onboarding customers, processing payments, handling funds, managing business relationships, or providing services that may be exposed to financial crime risk.

Where the organisation falls within the regulated sector, this Policy shall apply in conjunction with the Money Laundering Regulations and guidance from supervisory bodies.

Policy Statement

The organisation will not tolerate money laundering, terrorist financing or the concealment of criminal property. It will take all reasonable steps to identify, assess, monitor and mitigate the risk of financial crime.

Conduct risk-based customer due diligence (CDD) and enhanced due diligence (EDD) where applicable.

Identify and verify the identity of customers and beneficial owners before entering into a business relationship.

Maintain appropriate records to evidence CDD, transactions and decisions.

Report suspicious activity to the firm’s Money Laundering Reporting Officer (MLRO).

Legislative and Regulatory Framework

Proceeds of Crime Act 2002 (POCA)

Terrorism Act 2000

Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)

Criminal Finances Act 2017

Sanctions and Anti-Money Laundering Act 2018

Relevant sectoral guidance issued by UK supervisory authorities and the UK National Risk Assessment

Roles and Responsibilities

The Board shall approve this Policy and ensure adequate resources for AML compliance.

A Money Laundering Reporting Officer (MLRO) shall be appointed to receive internal suspicious activity reports (SARs), consider them and, where appropriate, submit Suspicious Activity Reports to the National Crime Agency (NCA).

All employees must complete AML training and promptly report any knowledge or suspicion of money laundering.

Risk-Based Approach

The organisation shall conduct an institutional AML risk assessment considering products, services, delivery channels, geography, and customer types.

Higher-risk circumstances (e.g. politically exposed persons, complex ownership structures, high-risk jurisdictions) shall be subject to enhanced due diligence and senior management approval.

Customer Due Diligence

CDD shall be conducted before establishing a business relationship or carrying out an occasional transaction above the applicable threshold.

CDD shall include identifying the customer, verifying identity on the basis of reliable, independent source documents or data, and understanding the purpose and intended nature of the business relationship.

Where the customer is a body corporate, beneficial ownership shall be identified and verified.

Ongoing Monitoring

Transactions and business relationships shall be monitored on a risk-sensitive basis to ensure they are consistent with the organisation’s knowledge of the customer, their business and risk profile.

Unusual or suspicious activity shall be escalated to the MLRO.

Reporting

Any employee who knows or suspects, or has reasonable grounds for knowing or suspecting, that a person is engaged in money laundering must make an internal report to the MLRO without delay.

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