1. Placement– This is the movement of cash from its source into another institute or entity.
  2. Layering – this is where the process is more complicated, the cash is converted into other monetary instruments.
  3. Integration/extraction – false entities are set up to appear legitimate for secret transaction or to lend back.

Carrying out customer due diligence requirements

We are obliged to carry out customer due diligence by taking the necessary steps to identify our customers. This means obtaining a customer’s:

  • name
  • official photograph document to confirms their identity
  • their residential address and date of birth

we require a government issued document i.e a passport, utility bills, bank statements or any other official documents. Other sources could be electoral register and information from credit reference agencies such as Experian, Equifax and any other to identify the person.

 Applying customer due diligence measures

We are obliged to carry customer due diligence checks as listed on gov.uk website:

  • when you establish a business relationship with a customer (or another party in a property sale)
  • when you suspect money laundering or terrorist financing
  • when you have doubts about a customer’s identification information that you obtained previously
  • when it’s necessary for existing customers – for example if their circumstances change
  • if you are not a high value dealer, when you carry out an ‘occasional transaction’ worth €15,000 or more
  • as a high value dealer, when you:
    • make a payment to a supplier worth €10,000 or more
    • carry out an ‘occasional transaction’ worth €10,000 or more

Our obligation when establishing a business relationship 

Any business relationship we seek to enter with a customer where both of us expect the relationship to be any term (short/medium or long term). It can also be formal or an informal arrangement between the parties. We need the following information as listed on gov.uk website:

  • the purpose of the relationship
  • the intended nature of the relationship – for example where funds will come from, the purpose of transactions, and so on

The type of information that you need to obtain may include:

  • details of your customer’s business or employment
  • the source and origin of funds that your customer will be using in the relationship
  • copies of recent and current financial statements
  • details of the relationships between signatories and any underlying beneficial owners
  • the expected level and type of activity that will take place in your relationship

For further information please visit the government website gov.uk for details on;

The changing circumstances of customers

When to apply due to occasional transactions

When to carry out enhance due diligence

We are obligated by law to report transaction of any amount that appears suspicious in nature. 

When customer is another Money Service Business

Training of our staff or demanding third parties’ partners are qualified to thoroughly carry out checks.

We are committed to train and keep record of certain individual or associates or employees so they’re aware of their responsibilities to protect the business to trade legally and sustain the law.

We would ask for proof as to where any cask sum monetary was generated and have our solicitor or account to make checks as necessary.

We would keep a record of our dealings and transaction, receipts, email or any correspondences, computerised, originals and photocopy documents where appropriate for 5 years from the end of a business relationship or and a transaction is completed.