hese are the Anti-Money Laundering (AML) Policy and Procedures adopted by “Top Connect Limited” in compliance with The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR). Top Connect has developed a comprehensive compliance and anti-money laundering programme that is used throughout its network to ensure full compliance with all relevant rules and regulation. We recognise the importance of complying with all anti-money laundering laws and combating the financing of terrorism.
Top Connect Ltd is committed to establishing and maintaining effective arrangements to prevent and detect attempts to launder money using Top Connect Ltd services. Top Connect Ltd requires all Members and employees to demonstrate the highest standards of honesty and integrity and this includes compliance with appropriate legislation.
Top Connect Ltd is committed to working constructively with all relevant agencies in relation to combating money laundering and ensuring compliance with the legislation. Top Connect Ltd understands that the best way to fulfil this commitment is to establish effective internal policies and procedures to notify whenever it has suspicions of any criminal activity by individuals engaged in a money transfer transaction. Top Connect Ltd has adopted strict compliance of all applicable AML rules and regulations with specific emphasis on POCA, The Money Laundering and Terrorist Financing (amendment) Regulations 2019 (MLRs). A breach of these procedures may lead to disciplinary and/or criminal action being taken.
AS A MONEY SERVICE BUSINESS, WE ARE SUBJECT TO THE FOLLOWING REGULATIONS:
REPORTING
We are required to report the following types of transactions to the authorities, Suspicious Activity (SAR)
RECORD KEEPING
We are required to keep all client, transaction and corporate records for a minimum of 5 years.
ASCERTAINING IDENTITY
We are required to collect and verify your identification regardless of the amount sent, No ID No transfer.
THIRD PARTY DETERMINATION
If you are conducting a transaction on someone else’s behalf, we are required to obtain information on both parties: you and the person on whose behalf you are conducting the transaction.
COMPLIANCE PROGRAM
We are required to maintain a compliance program containing adequate policies and procedures in accordance with the applicable regulations. For more information, refer to FCA and FATF websites:
ADDITIONAL MEASURES WE TAKE TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING
WE TAKE THE FOLLOWING ADDITIONAL MEASURES TO PREVENT MONEY LAUNDERING AND TERRORIST FINANCING
SCANNING AGAINST THE HM TREASURY WATCH LIST
It is our policy to check each transaction against the HM Treasury watch list and OFAC and UN sanction Lists.
TRANSACTION MONITORING
We have adequate controls pertaining to the transaction activity at several instances of the life cycle of a transaction. These controls include:
Client Profiling
Risk Assessment
Client Identification Controls & Validations
Transaction Aggregation Thresholds
Government Reporting Controls & Validations
Possible Structuring Reporting
Enhanced Due Diligence Reporting
Training
All affected employees are provided with training that explains The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, The Proceeds of Crime Act 2002 and section 18 and 21A Terrorism Act 2000, and that these affect the firm, its clients and its employees.
All affected employees are further trained on their responsibilities in relation to money laundering legislation and are aware of how to identify and deal with transactions that may involve money laundering.