Policy Statement

Position One Motor Company is dedicated to full compliance with all applicable laws and regulations regarding anti-money laundering (AML) in the United Kingdom. We implement stringent measures to detect, prevent, and report any transactions or activities that may involve money laundering or terrorist financing. Our company is committed to upholding the integrity of our business operations and maintaining the trust of our customers.

Purpose

The objective of this policy is to outline the key standards and principles that Position One Motor Company follows to prevent involvement in money laundering activities. It also ensures that our employees are well-equipped with the necessary knowledge to recognize and prevent such activities.

Scope

This policy applies to all employees, directors, officers, and business partners of Position One Motor Company. Compliance with this policy is mandatory for all staff, regardless of their role within the company.

Definitions

  • Money Laundering: The act of disguising the origins of illegally obtained money to make it appear legitimate. This process typically consists of three stages: placement, layering, and integration.
  • Terrorist Financing: The provision of financial support to individuals or organizations engaged in terrorist activities.
  • Suspicious Activity: Any transaction or behavior that deviates from the normal pattern of activity or is inconsistent with the known customer’s legitimate business dealings.

Customer Due Diligence (CDD)

  • Before establishing any business relationship, Position One Motor Company will conduct thorough due diligence on potential customers. This includes verifying their identity and understanding their business and financial activities.
  • Enhanced due diligence will be conducted for high-risk customers, such as politically exposed persons or individuals from jurisdictions with heightened money laundering risks.

Employee Training and Awareness

  • All employees will receive regular training on AML regulations, how to recognize suspicious activities, and the correct procedures for reporting them.
  • Training programs will be updated to align with changes in legislation, regulatory guidelines, and emerging money laundering threats.

Reporting Suspicious Activities

  • Employees must promptly report any suspicious activities or transactions to the designated Money Laundering Reporting Officer (MLRO).
  • The MLRO is responsible for evaluating reported concerns and, if necessary, submitting a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

Record Keeping

  • All financial transactions and customer-related records obtained through CDD measures will be retained for a minimum of five years, in compliance with legal and regulatory requirements.

Compliance and Monitoring

  • Regular audits and reviews will be conducted to ensure adherence to this policy and assess the effectiveness of AML measures in place.
  • Any employee found to be non-compliant with this policy will face disciplinary action, which may include termination of employment.

Policy Review and Update

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

 

By adhering to this Anti-Money Laundering Policy, Position One Motor Company reaffirms its commitment to conducting business with integrity, upholding the highest ethical standards, and contributing to the global fight against money laundering and terrorist financing.