Anti-Money Laundering & Know Your Counterparty (KYC)
This policy confirms [SeptechUK Ltd]’s commitment to prevent money-laundering and the financing of terrorism in its business practices and transactions. Money laundering is the process of disguising the financial proceeds of crime to conceal their illegal origin. The financing of terrorism is any kind of financial support to those who attempt to encourage, plan or engage in terrorism.
[SeptechUK Ltd] has established Know Your Counterparty (KYC) procedures to combat money laundering and the financing of terrorism. These procedures allow us to identify every organisation that we deal with, to understand the legitimacy of our business relationships and to identify and react to unusual or suspicious activity.
[Please note: If this policy will be made public ie on your website, it is not recommended to name the senior manager responsible but to either put their title or function only.]
[Please note: Make sure that your KYC policy and procedures are overseen by a suitably qualified and experienced individual with:
- expertise in your industry,
- awareness of key counterparties; and
- good knowledge of money laundering techniques, including how they might be used in your industry’s transactions and areas of operation]
To support our KYC policy and procedures, [SeptechUK Ltd] has developed a KYC form which we send to all our counterparties (this is our business partners: suppliers and customers) to collect relevant business information to identify risks of money-laundering. We require the form to be completed for all existing and new counterparties.
[Please note: If your KYC forms have been combined with your supply chain information requests for COP7 on Due Diligence, you should note this here.]
By collecting and reviewing the information in completed KYC forms, [SeptechUK Ltd] commits to
- establishing the identity of our counterparties
- checking that our counterparties are not considered high-risk (this means checking whether counterparties are based in FATF high-risk jurisdictions, named on government sponsored watchlists or international (UN) sanctions lists, or if they source from conflict-affected and high-risk areas (CAHRAs))
- maintaining an understanding of the nature and legitimacy of all our counterparties’ businesses
- maintaining KYC records for at least five years
- maintaining records of all single or linked cash (or cash-like) transactions above 10,000GBP
- monitoring transactions for unusual or suspicious activity – this type of activity will cause the counterparty to be considered high-risk.
If counterparties are considered high-risk for any reason (for example named on a sanctions list or engaging in unusual activity) we may:
- Cease trading with the counterparty
- Identify the beneficial owners of the counterparty and check whether the beneficial owners are on any watchlists or sanctions list
- Make an on-site visit to the high-risk counterparty.
[Please note: It is the responsibility of each member to add details and information specific to its procedures and actions to meet the KYC policy. This may include reference to:
- additional legal requirements and how they’re met
- how you report suspicious activity to the (named) designated authority
- the training you give to relevant employees
- whether you use a KYC database, software program or other service as part of your KYC procedures
- any monitoring controls that are in place.]
Addressing of Grievances
Any complaint or grievance relating to the processing of information, should be sent in writing to SeptechUK. Please see below for contact information.
Filing a Grievance:
SEPTECHUK LTD
Email: [email protected]
244 Chase Road,
N14 6HH
London, United Kingdom
Policy Changes
From time to time, this policy may change. Please check back periodically for any updates or changes to this page.
This document was last updated on 18.02.2023