Anti-Money Laundering (AML) Policy
Introduction
I, Ryan Jarvis, trading as Ryan Jarvis Law®, am committed to complying with the Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, the Terrorism Act 2000, and the relevant guidance provided by CILEx Regulation. This policy outlines the procedures and controls in place to prevent money laundering and terrorist financing activities.
Scope
This policy applies to all employees, consultants, and contractors of Ryan Jarvis Law®. It covers all aspects of our legal services and applies to all clients and third parties involved in our transactions.
Objectives
To prevent the firm from being used for money laundering or terrorist financing.
To ensure compliance with all relevant laws and regulations.
To protect the firm’s reputation and maintain the integrity of the legal profession.
Responsibilities
Money Laundering Reporting Officer (MLRO)
I, Ryan Jarvis, am the designated MLRO for Ryan Jarvis Law®. My responsibilities include:
Implementing and maintaining this AML policy.
Receiving and assessing internal reports of suspicious activity.
Reporting suspicious activity to the National Crime Agency (NCA).
Ensuring that all staff receive appropriate AML training.
Staff Responsibilities
All staff members are required to:
Follow the procedures outlined in this policy.
Report any suspicions of money laundering or terrorist financing to the MLRO.
Complete regular AML training.
Client Due Diligence (CDD)
Identification and Verification
Before establishing a business relationship or carrying out a transaction, we will:
Identify the client by obtaining their name, date of birth, and address.
Verify the client’s identity using reliable, independent source documents, data, or information (e.g., passport, driving licence, utility bill).
Enhanced Due Diligence (EDD)
We will apply enhanced due diligence measures in higher risk situations, including:
Clients who are not physically present.
Politically exposed persons (PEPs).
Clients from high-risk jurisdictions.
Complex or unusually large transactions.
Ongoing Monitoring
We will conduct ongoing monitoring of our business relationships to:
Ensure that transactions are consistent with our knowledge of the client.
Identify any changes in the client’s risk profile.
Detect and report suspicious activities.
Reporting Suspicious Activity
Internal Reporting
All staff must report any suspicions of money laundering or terrorist financing to the MLRO as soon as possible. The report should include:
The identity of the client.
The nature of the suspicious activity.
The reasons for suspicion.
Reporting to the NCA
If the MLRO determines that a report is necessary, they will submit a Suspicious Activity Report (SAR) to the NCA. The MLRO will:
Provide all relevant information to the NCA.
Act on any instructions received from the NCA.
Record Keeping
We will maintain records of:
Client identification and verification documents.
Details of all transactions.
Internal and external reports of suspicious activity.
Training records.
These records will be kept for at least five years after the end of the business relationship or transaction.
Training
All staff will receive regular training on AML laws and regulations, including:
How to identify and report suspicious activity.
The importance of CDD and EDD.
The firm’s AML procedures.
Risk Assessment
We will conduct regular risk assessments to:
Identify and assess the risks of money laundering and terrorist financing.
Implement appropriate measures to mitigate these risks.
Review and Updates
This policy will be reviewed annually or when there are significant changes in relevant legislation or guidance. Updates will be communicated to all staff, and additional training will be provided if necessary.
Contact Information
If you have any questions about this AML policy, please contact:
Ryan Jarvis
Ryan Jarvis Law®
Postal Point 428
Manchester
M8 2FS
Email: ryan.jarvis@ryanjarvis.law
Phone: 0161 528 9071
This anti-money laundering policy was last updated on 20th May 2024.