AML & KYC Policy

1. Policy Overview

This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy applies to all users of the SupplierHub platform, including Buyers and Suppliers. Our commitment includes:

• Verifying the identity of all platform users
• Monitoring transactions for suspicious activity
• Reporting suspicious transactions to relevant authorities
• Maintaining records as required by law
• Training staff on AML compliance
• Regular policy reviews and updates

2. Know Your Customer (KYC) Requirements

2.1 Business Verification (Suppliers)

All Suppliers must complete business verification before listing products:

2.2 Enhanced Due Diligence (EDD)

Additional verification is required for:

• High-risk jurisdictions (as defined by FATF)
• High-volume suppliers (over €10,000/month)
• Politically Exposed Persons (PEPs)
• Complex corporate structures
• Cash-intensive businesses

EDD may include: Source of funds verification, additional documentation, senior management approval, and enhanced ongoing monitoring.

3. Transaction Monitoring

3.1 Monitoring Thresholds

We monitor all transactions and apply enhanced scrutiny to:

• Single transactions exceeding €10,000
• Multiple related transactions exceeding €10,000 in 24 hours
• Unusual patterns (frequency, volume, or nature)
• Transactions involving high-risk jurisdictions
• Cryptocurrency transactions over €5,000

3.2 Red Flags

We investigate transactions that exhibit the following characteristics:

• Rapid increase in transaction volume without business justification
• Structuring transactions to avoid reporting thresholds
• Transactions inconsistent with stated business profile
• Round-dollar amounts or unusual patterns
• Transactions atypical for the user's geographic location
• Use of multiple accounts without valid reason
• Frequent changes to bank account information

4. Suspicious Activity Reporting

4.1 Internal Reporting

All staff are trained to identify and report suspicious activity to our Money Laundering Reporting Officer (MLRO). Reports must be made within 24 hours of detection.

4.2 External Reporting

We are legally obligated to report suspicious transactions to:

• NCA (National Crime Agency): Suspicious Activity Reports (SARs) within UK
• FCA (Financial Conduct Authority): Where applicable
• HMRC: For MLR 2017 compliance matters

5. Record Keeping

5.1 Retention Periods

We maintain records for the following periods:

• Customer identification records: 5 years after relationship ends
• Transaction records: 5 years from transaction date
• AML training records: Duration of employment plus 5 years
• Risk assessments: 5 years from assessment date

5.2 Record Types

Records maintained include:

• Copies of identification documents
• Business verification documents
• Transaction history and supporting documents
• Correspondence related to verification
• Risk assessments and monitoring results
• SARs and internal reports

6. Sanctions Compliance

6.1 Prohibited Jurisdictions

We do not onboard users or process transactions from individuals or entities in:

• Countries under UK/EU/UN sanctions
• High-risk jurisdictions per FATF grey/black lists
• Jurisdictions with inadequate AML controls

6.2 Sanctions Screening

All users are screened against:

• UK Sanctions List (OFSI)
• EU Consolidated List
• UN Security Council Sanctions
• US OFAC SDN List
• Interpol Wanted Lists

7. User Responsibilities

7.1 Supplier Obligations

Suppliers must:

• Provide accurate and truthful information during verification
• Notify us of any changes to business structure or ownership within 14 days
• Report lost or stolen credentials immediately
• Cooperate with any AML investigations
• Ensure products sold are from legitimate sources

7.2 Prohibited Activities

Users are prohibited from:

• Using the platform for money laundering or terrorist financing
• Providing false or forged documents
• Using the platform to circumvent sanctions
• Operating multiple accounts to evade detection
• Facilitating transactions for third parties (layering)

8. Compliance Actions

8.1 Account Restrictions

We may take the following actions when AML concerns arise:

• Temporary suspension: Pending verification of suspicious activity
• Transaction limits: Reduced until EDD completed
• Enhanced monitoring: All transactions manually reviewed
• Permanent termination: For confirmed AML violations

8.2 Fund Freezing

In cases of suspected criminal activity, we may:

• Freeze pending withdrawals pending investigation
• Block transactions to/from certain jurisdictions
• Report to law enforcement authorities

Users will be notified of any restrictions as permitted by law.

9. Training and Governance

9.1 Staff Training

All employees receive:

• Initial AML training upon hiring
• Annual refresher training
• Specialized training for customer-facing roles
• Updates when regulations change

9.2 Money Laundering Reporting Officer

Our MLRO is responsible for:

• Overseeing AML compliance
• Reviewing suspicious activity reports
• Making decisions on SAR submissions
• Liaising with regulatory authorities
• Ensuring policy updates

10. Policy Review

This AML/KYC Policy is reviewed annually and updated as necessary to reflect:

• Changes in legislation or regulation
• Updates to FATF recommendations
• Changes in business operations
• Emerging risks and typologies
• Findings from internal audits

11. Contact Information

For AML-related inquiries or to report suspicious activity:

For emergencies involving suspected criminal activity, contact law enforcement directly.