1. Policy Statement

Surrey Hills Motor Company is committed to fully complying with all applicable laws and regulations regarding anti-money laundering (AML) within the United Kingdom. Our company adopts stringent measures to detect, prevent, and report any activities or transactions that may involve money laundering or terrorist financing. We are dedicated to ensuring the integrity and security of our business operations and maintaining the trust of our customers.

  1. Purpose

The purpose of this policy is to establish the essential standards and principles to prevent the involvement of Surrey Hills Motor Company in money laundering activities and to ensure our employees are equipped with sufficient knowledge to identify and prevent such activities.

  1. Scope

This policy applies to all employees, directors, officers, and business partners of Surrey Hills Motor Company. Compliance with this policy is mandatory for all staff members, irrespective of their position or role within the company.

  1. Definitions

– Money Laundering: The process of making illegally-gained proceeds appear legal by disguising their original source. This process is divided into three stages: placement, layering, and integration.

– Terrorist Financing: Providing financial support to individuals or organisations engaged in terrorist activities.

– Suspicious Activity: Any transaction or behaviour that does not conform to the usual pattern of activity or is inconsistent with the known customer’s legitimate business activities.

  1. Customer Due Diligence (CDD)

– Before entering into any business relationship, Surrey Hills Motor Company will conduct due diligence on prospective customers. This includes verifying the identity of our customers and understanding the nature of their business and financial activities.

– Enhanced due diligence will be applied to customers presenting a higher risk, such as those involved in politically exposed positions or those from high-risk jurisdictions.

  1. Employee Training and Awareness

– All employees will receive regular training on AML regulations, the recognition of suspicious activities, and the proper way to report them.

– Training will be updated to reflect changes in legislation, regulatory guidance, or the emergence of new money laundering threats and techniques.

  1. Reporting Suspicious Activities

– Employees are required to immediately report any suspicious activities or transactions to the designated Money Laundering Reporting Officer (MLRO) within the company.

– The MLRO is responsible for assessing the reported information and, if appropriate, for filing a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).

  1. Record Keeping

– All financial transactions and customer-related information obtained through CDD measures will be retained for a minimum period of five years to comply with legal and regulatory requirements.

  1. Compliance and Monitoring

– Regular audits and reviews will be conducted to ensure compliance with this policy and the effectiveness of the AML measures in place.

– Non-compliance with this policy by any employee will result in disciplinary action and could lead to termination of employment.

  1. Policy Review and Update

– This policy will be reviewed annually or as needed to reflect changes in legislation, regulatory requirements, or company operations. Any amendments will be communicated promptly to all employees.

By adhering to this Anti-Money Laundering Policy, Surrey Hills Motor Company demonstrates its unwavering commitment to conducting business with integrity, adhering to the highest ethical standards, and actively participating in the global fight against money laundering and terrorist financing.