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Stephenson Browne Ltd Anti-Money Laundering Policy

Money laundering is a process that criminals use to make the original ownership and control of proceeds of crime ie; illegally gained funds, transform into legitimate capital. They endeavour to disguise how they have acquired the money and pass it through a series of commercial transactions to integrate them into less suspicious sources.

Stephenson Browne Ltd are committed to ensuring that we have adequate procedures in place to counteract money laundering and terrorist funding activities in line with the Money Laundering Regulations 2017 (amended 10 January 2020).

An assessment is necessary to minimise the risk of customers laundering money through our business activities.  We must identify criteria that will indicate a higher risk of money laundering.  An example of this is not meeting the client face to face at any point during the transaction.

As part of mitigating the risk, Stephenson Browne Limited recognises that it is essential for all staff to have a knowledge and understanding of anti-money laundering legislation and all staff are provided with training to enable them to understand the company’s responsibilities and how to identify risk.  Each member of staff is also provided with a copy of this Money Laundering Policy and a Risk Assessment, as a reminder of their responsibilities and where and how to report suspicious circumstances.

Our nominated Money Laundering Reporting Officer (MLRO) is Stephen Bird and Deputy Money Laundering Officer is Sarah Radford, whose responsibility it is to receive internal reports.  Our MLRO (or deputy) is then responsible for making a decision as to whether further due diligence is needed or whether to file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).