24/09/2025
OVERVIEW
We, Friendly Assist Accountancy- take a zero tolerance approach to being involved in illegal activity, and will fully comply with all relevant sections of the Money Laundering Regulations 2017 (ML Regs) in its as amended form by the Draft Money Laundering and Terrorist Financing (Amendment and Miscellaneous Provision) Regulations 2025 published on September 2, 2025, by HM Treasury and MLR 2019, the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000 (TACT).
All shareholder and stakeholders, employees, associates and any other person in relation to the firm are under an obligation and duty to comply with the above. This policy & any related procedures aim to provide a clear framework, along with setting out the firm’s key principles and obligations.
- Failure to fulfil these responsibilities may result in disciplinary action and may also result in criminal sanctions for the staff involved.
- Breaches may also be reportable to our AML Supervisor (AAT) which may result in professional disciplinary action.
- Furthermore, a report may also have to be made to the NCA or other law enforcement agencies, which may result in a criminal investigation.
AML LEGISLATIVE FRAMEWORK SECTION
Our Responsibilities according to legislation include:
- Enhanced Due Diligence and Ongoing Monitoring (incl. definition and treatment of PEPs) if unusually complex or unusually large transactions appear
- MLRO Responsibilities, SAR Reporting, Tipping Off, Police Orders
- Quality Assurance
- AML Record Keeping
- AML Training
- Risk Based Assessment
- Customer Due Diligence including Identification and Verification (ID&V) requirements, assessing Source of Wealth, application of know your customer (KYC) information
- Compliance with International Sanctions Requirements POCA 2002/TACT 2000: MLRO responsibilities, Suspicious Activity Reporting, Tipping Off & Police Orders
Key responsibilities of staff therefore include (but are not limited to)
- Conducting an adequate risk assessment and appropriate due diligence (CDD) on clients and transactions, including PEP and sanctions checking.
- Monitoring all clients/transactions on an ongoing basis for potential money laundering or terrorist financing activity.
- Report any suspicious client or transaction activity to the MLRO as per the firm’s SAR procedure.
- Avoiding discussing any potential or actual SARs with clients or any third parties (“Tipping off”).
- Referring any Police/Law Enforcement queries or requests to the MLRO.
- Undertaking any AML-related training provided
- Keeping appropriate records of all AML related activity
Friendly Assist Accountancy Ltd – RISK PROFILE SECTION:
The directors believe we; Friendly Assist Accountancy Ltd. are at a medium risk of being used to launder the proceeds of crime.
This is based on the following factors:
• International activities of current client base
RISK BASED ASSESSMENT SECTION:
- see resp. refer to Friendly Assist Accountancy Ltd. Risk Assessment Procedure
- see resp. refer to High level overview of risk factors/ “red flag indicators” and red flag follow up
- see resp. refer to Firm policy regarding international clients and their transactions – especially from non-EU countries
Nominated Officer and Deputy to Nominated officer
Steffen Kemmerzehl is nominated officer, also called MLRO, for AML and responsible for all procedures. All other directors function as deputy to this position.
All communication regarding AML procedures are to be conducted in writing and signed by the nominated officer
CUSTOMER DUE DILIGENCE PROCEDURES SECTION
- Responsible for any Customer Due Diligence procedures is Director and Accountant Steffen Kemmerzehl – he is also the nominated officer for AML
- All ID&V procedures are to be completed within the Onboarding of a client – yearly checks are to be conducted
- Standard Procedures – If client is a private individual:
ID of person via passport, driving license, national ID card to be checked
ID of spouse and any adult children are to be checked as above
Video chat to doublecheck and verify ID needed within Onboarding
If client is a Company, Trust, or any other legal entity:
ID of all persons with significant control
Video chat to doublecheck and verify ID needed within Onboarding - These procedures can be simplified, if Client is UK resident, UK listed and regulated company
Here client due diligence only necessary if risk is evaluated to be medium or higher - Enhanced due diligence – If client is non-UK resident by time of Onboarding or if risk is evaluated to be medium or higher
In addition to Standard a regular, at least monthly, monitoring of transactions is to be applied
Risk is to be evaluated at least quarterly. If Risk is assessed to be medium or higher for more than 2 quarters – DBS check is to be requested on cost of client - No R.17 reliance is applied – all CDD procedures are to be processed by Friendly Assist Accountancy Ltd
- Electronic Verification is to be conducted based on Risk Assessment of the client
- CDD is to be applied to any 3rd Party Funding if they are to be assessed as having a risk higher than low and are not immediate family of the client(s)
- Friendly Assist Accountancy is not handling any client moneys
Politically exposed persons (PEPs)
The firm will apply enhanced and ongoing due diligence to all PEP clients and will consider and assess the heightened risk of undertaking business with or on behalf of PEPs, particularly the risk of laundering the proceeds of corruption.
What is a PEP?
- A “politically exposed person” (PEP) is a term describing someone who has been entrusted with a prominent public function.
- A PEP generally presents a higher risk for potential involvement in bribery and corruption by virtue of their position and the influence that they may hold.
- Positions may include:
Head of state, heads of government, ministers and deputy or assistant ministers
Members of parliament
Members of supreme courts, of constitutional courts, or of other high-level judicial bodies – members of courts of auditors or of the boards of central banks
Ambassadors, charges d’affairs and high-ranking officers in the armed forces
Members of the administrative, management or supervisory bodies of state-owned enterprises
High ranked members of any religious community
Any Mayors
Any members of Political Councils
Any publicly known person regularly covered by the media - The definition of a PEP also extends to:
family members of a PEP – spouse, partner, children and their spouses or partners, and parents – known close associates of a PEP
– persons with whom joint beneficial ownership of a legal entity or legal arrangement is held,
– with whom there are close business relationships, or who is a sole beneficial owner of a legal entity or arrangement set up by the primary PEP
International Sanctions Checking:
We, Friendly Assist Accountancy Ltd., will conduct a sanctions list check on each new client via the HM Treasury website (or an electronic verification system if used) to check if the client or source of funds is related to a sanctioned jurisdiction/regime, and conduct ongoing checks periodically (at least annually for all clients)
• https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-targets
This policy is to be quality checked and updated at least every year or in the event of a high-risk assessment of any client
AML RECORD KEEPING SECTION
All records in regards to AML are to be stored following AAT’s guidance
AML TRAINING SECTION
Nominated officer is required to regular undertake CPDs to keep up to date with AML processes.
Further shareholders and stakeholders of Friendly Assist Accountancy Ltd. Are to be advised in writing yearly of AML procedures