- 174 Cricklewood Broadway London NW2 3EB
- Monday to Friday: 9am to 5:30pm
This guidance is made to outlay the importance of complying with the law and defining Anti Money Laundering (AML), Counter Terrorist Finance (CTF) and Counter Fraud Procedures. It will also include a brief description of the policies and procedures. Sanction list and risk-based approach will be explained with examples of how money can be laundered and how to stop it.
This guide will helps us:
Under the Money Laundering and Terrorist Financing Regulations 2019 (MLRs), the company is obliged to provide all members of staff training on the law relating to money laundering/counter terrorist financing. We ensure that all our staff member have read the legislation so that they are aware of the potential criminal offences and the penalties. Where appropriate, HMRC guidance on the legislation is included to avoid confusion. Staff will be tested on their knowledge of the law as we are obliged to ensure that they are aware of it.
RUB ENTERPRISES LTD LTD responsibilities is to maintain with the regulations. Therefore, RUB ENTERPRISES LTD LTD have appointed a Money Laundering Reporting Officer (MLRO)
who will carry out regular audit on compliance with the regulations such as
To get in touch with our compliance officer please see below email address and our office number
Mail: info@rubexchange.co.uk
Mob: 02084529189
All employees are given the appropriate training and are responsible for reading the AML manual, understanding their responsibilities, and acting accordingly. Ensure that company procedures are followed and all documentary evidence is obtained as specified in the manual. Ensure that all suspicious events are reported to MLRO. This training is conducted by the Compliance Officer or the compliance Trainer.
RUB ENTERPRISES LTD LTD is well aware of its obligation of safeguarding of funds as stated within the Electronic Money Regulations 2011 (EMRs) and Payment Services Regulations 2017 (PSRs).
The objective of the safeguarding rules is to consider what would happen to our client’s funds in the unlikely event that our firm went into administration.
When we receive funds in relation to a trade, the money is received into a client bank account. Those client accounts are not commingled with firm money and in the unlikely event of administration, no other creditors can have access to these funds. We conduct daily reconciliations to ensure that the client balances as per our internal records corresponds to the funds held in the client accounts.
The data protection legislation, i.e. The data protection act 2018 and the general data protection regulation (GDPR) governs the processing of information relating to individuals, including obtaining, holding, use or disclosure of information.
Personal data obtained by a business under the regulations may only be processed for the prevention of money laundering and terrorist financing unless use of the data is allowed by other legislation or after obtaining the consent of the data subject.
RUB ENTERPRISES LTD LTD has a Data Protection policy which covers that personal data will only be used for the purposes of preventing money laundering and terrorist financing and provide them with the information as required under article 13 of the GDPR.
Customer due diligence and transaction processing
Customer due diligence means taking steps to identify your customers and checking they are who they are by asking government issued photo document and an official document; such as passport, driving license, utility bill and bank statement. Other sources of customer information include the electoral register and information held by credit reference agencies such as Experian and Equifax.
Identifying all ‘beneficial owners’, where applicable, and taking adequate risk-based measures to verify their identity. This may be because you need to establish the ownership structure of a company, partnership or trust. The beneficial owner is the person who’s behind the customer and who owns or controls the customer or it’s the customer on whose behalf a transaction or activity is carried out.
If you have doubts about a customer’s identity then you must stop dealing with them until you are sure
RUB ENTERPRISES LTD LTD must carry out customer due diligence measures as our business carries out occasional transactions. These are transactions that are not carried out within an ongoing business relationship where the value is:
This applies whether it’s a single transaction or linked transactions.
If we find that customer is not complying while performing the customer due diligence measures, then we do not: –
As part of our customer due diligence measures, we identify individuals. We obtain a private individual’s full name, date of birth and residential address as a minimum. We verify these using current government issued documents with the customer’s full name and photo, with a customer’s date of birth or residential address such as: –
A government issued document (without a photo) which includes the customer’s full name and also secondary evidence of the customer’s address, for example an old-style driving licence or recent evidence of entitlement to state or local authority funded benefit such as housing benefit, council tax benefit, pension, tax credit.
Secondary evidence of the customer’s address, not downloaded from the internet, for example a utility bill, bank, building society or credit union statement or a most recent mortgage statement.
If RUB ENTERPRISES LTD verify the customer’s identity by documents, RUB ENTERPRISES LTD see the originals and not accept photocopies, nor accept downloads of bills, unless certified as described below: –
Photocopy’s identity documents can be accepted as evidence provided that each copy document has an original certification by an appropriate person to confirm that it is a true copy and the person is who they say they are for standard customer due diligence an appropriate person is for example a bank, financial institution, solicitor or notary, independent professional person, a family doctor, chartered accountant, civil servant, or minister of religion.
RUB ENTERPRISES LTD check the documents to satisfy yourself of the customer’s identity. This may include checking: –
If a member of our staff has visited an individual at their home address. A record of their visit may corroborate the individual’s residential address (instead of the need for a second document). This should be covered in the risk assessment.
Where an agent, representative or any other person acts on behalf of the customer we ensure that they are authorised to do so, identify them and verify the identity using documents from a reliable and independent source.
KYC & KYB requirement are key aspects in RUB ENTERPRISES LTD relationships with its clients. The requirement to carry out customer due diligence and enhanced due diligence has given it an increased importance as it needs taking steps to identify your customers and checking they are who they say they are. KYC is a keystone in the fight against money laundering, serving to ensure our dealings are with genuine customers and organisations, and assisting in the identification of suspicious behaviour.
Obtaining the KYC information is only the first step to understanding with whom we are dealing. RUB ENTERPRISES LTD LTD system is designed in a way that it continuously reviews the customers data with Risk Based approach in mind and when its necessary system will automatically request additional information on that customer account. This is to enable you to know enough about the customer and it is reasonably satisfied that they are genuine and do not pose a significant money laundering risk. You should therefore apply this policy with this objective in mind.
