# ANTI-MONEY LAUNDERING POLICY
Date: 10 July 2030
Parties: Northmoor Accountancy Limited and its staff
## 1. Purpose and parties
Northmoor Accountancy Limited provides bookkeeping, tax advice and company-formation services from Leeds. It is supervised by HMRC for activities within the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017. This policy applies to those services, not automatically to every business or every low-risk administrative task.
## 2. Facts, scope and terms
The MLRO is Priya Shah and the deputy is Oliver Grant. The board approves a business-wide risk assessment covering customers, countries, services, delivery channels and transactions. Risk is low, medium or high with documented rationale; a new product, ownership change, adverse intelligence or incident triggers reassessment.
## 3. Process and responsibilities
Before an in-scope relationship, staff identify and verify the customer, beneficial owners and persons acting for a company. Standard CDD uses reliable identity and address evidence; enhanced due diligence applies to a PEP, high-risk country, opaque structure or unusual transaction. Simplified measures are used only where legally permitted and documented.
## 4. Evidence, records and safeguards
Files record purpose, expected activity, source of funds where risk requires it, screening, approvals and ongoing monitoring. Staff refresh identity on a risk basis and escalate unexplained complexity, rapid movement of funds or inconsistent instructions. Records are retained for five years after the relationship ends unless law requires longer.
## 5. Review, escalation and outcome
A staff member sends an internal suspicious-activity report to the MLRO promptly and must not tip off the customer. The MLRO decides whether a report to the National Crime Agency via SARs Online, including a Defence Against Money Laundering request where relevant, is required. Staff are protected when reporting in good faith and must follow lawful instructions.
## 6. Reservations and practical protections
All relevant staff receive induction and annual AML training; the MLRO tests completion and keeps a breach log. The policy does not tell staff to investigate crime themselves, disclose a SAR, or reject a customer solely on a protected characteristic. Questions go to the MLRO, with audit and board oversight.
## 7. England and Wales law and completion
The policy is reviewed every year and after regulatory change. It preserves legal professional privilege where applicable, data-protection duties and record-security controls. England and Wales law applies. Priya Shah approves version 3.0 on 10 July 2030.