Legal

Financial crime & anti-money laundering policy

JMP Group Limited, trading as Vale Verandas.

1. About this policy

1.1JMP Group Limited, trading as Vale Verandas (we/us/our), is committed to complying with the legislation, regulations and associated guidance that govern our business, and to ensuring that all of our staff adhere to our anti-money laundering (AML) requirements.
1.2All staff are required to read, understand and implement the procedures set out in this policy. Failure to adhere to this policy may lead to disciplinary action. Anyone who is unsure about any aspect of this policy should speak to a manager.
1.3This policy should be read alongside our Terms & conditions and Privacy policy.

3.1Money laundering is the act of hiding the original ownership of money that has been obtained through criminal activity, such as terrorism, corruption or fraud, and then moving it through legitimate businesses and sources to make it appear “clean”.
3.2
Money laundering has three fundamental stages:
1. 3.2.1Placement — getting “illicit funds” into the financial system;
2. 3.2.2Layering — using transactions of different types to help disguise the origins of the funds; and
3. 3.2.3Integration — completing transactions that fully integrate the “illicit funds” into the financial system, resulting in “clean” (laundered) money.

4.1
We operate under and comply with the applicable UK law, acts and regulations with regard to our anti-money laundering policy and procedures, including:
1. 4.1.1Proceeds of Crime Act 2002 (POCA);
2. 4.1.2Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the Money Laundering Regulations 2017); and
3. 4.1.3the Money Laundering and Terrorist Financing (Amendment) Regulations 2019.
4.2
We also take account of the following guidance:
1. 4.2.1the FCA Handbook (SYSC 3.2.6 and SYSC 6.6.1); and
2. 4.2.2the Joint Money Laundering Steering Group (JMLSG) guidance.

5.1
To prevent financial crime and money laundering within our business, we:
1. 5.1.1ensure all relevant staff have read and understood this policy;
2. 5.1.2ensure all staff remain vigilant for the signs of money laundering;
3. 5.1.3do not accept cash deposits greater than €10,000 (see below);
4. 5.1.4carry out due diligence regarding customer identification by following the relevant operating instructions, whether that is of our business or of any partner business;
5. 5.1.5carry out risk assessments and audits of all AML requirements and procedures as appropriate to our business;
6. 5.1.6ensure the reporting of any suspicion of money laundering to a company Director or Money Laundering Reporting Officer (MLO) where we have one;
7. 5.1.7report any suspected or detected money laundering to the National Crime Agency when appropriate to do so;
8. 5.1.8maintain records of staff training and of any suspicions or detection of money laundering; and
9. 5.1.9appoint an MLO if the business were to become required to register under the Money Laundering Regulations.
5.2If cash deposits greater than €10,000 were to be taken, the business would register under the Money Laundering Regulations and publish a revised full financial crime policy in accordance with those Regulations.

6.1There is a fundamental requirement to identify customers and verify their identity through customer due diligence (CDD), for individuals or businesses.
6.2
We can accept the following identification documents:
1. 6.2.1individuals — driving licence, passport, bank statement or utility bill;
2. 6.2.2businesses — director or proprietor ID, certificate of incorporation, company registration number and registered office, utility bill, supplier invoice or bank statement.
6.3Depending on the documents seen, one or more may be required, and third-party verification may also be required.
6.4Where a customer is using consumer credit with our partner lender(s), we will follow their operating procedures regarding CDD in identifying customers.
6.5Due diligence checks are obligatory in the UK when a single transaction exceeds €15,000, or where doubt exists about the identity or reliability of the customer.

7.1We must be satisfied that we know who the beneficial owner of a business is — a person who owns or controls more than 25% of the business, even indirectly.
7.2Where we have an ongoing business relationship, there is a requirement to obtain information regarding the purpose of any transactions and the source of any funds.

8.1Client identification procedures — customer identity due diligence is carried out on all new customers.
8.2Traceable transactions — all transactions carried out by the business are recorded in such a manner that their origin can be traced should the need arise.
8.3Records management — all documents, accounts and transactions associated with our sales are retained as per the legal or statutory retention periods, which currently stands at “close of account + 5 years”.
8.4Reporting — where required, we monitor all anti-money laundering activity and report suspicions to the appropriate authorities.

9.1If you have any questions about this policy, please contact us by email at enquiries@valeverandas.co.uk or by phone on 01446 310 103.
9.2JMP Group Limited reserves the right to change this policy as we may deem necessary from time to time or as may be required by law. Any changes will be posted on this website.

Questions about this policy? Contact us.