Last updated on the 15th of October 2023.

1. Introduction.

The Proceeds of Crime Act 2002 (POCA) consolidated, updated, and reformed criminal law with regard to money laundering. Aston Card Limited will take reasonable steps to minimize the likelihood of money laundering occurring by putting in place proper policies and procedures. This policy has therefore been adopted to introduce safeguards to help identify and report instances where money laundering is suspected.

2. Scope of the Policy.

This Policy applies to all employees of Aston Card Limited and aims to maintain the high standards of conduct by preventing criminal activity through money laundering. The policy sets out the procedures that must be followed (for example, the reporting of suspicions of money laundering activity) to enable Aston Card Limited to comply with its legal obligations.

3. Definition of Money Laundering.

Money laundering can be defined as the process of moving illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offenses include concealing, disguising, converting, transferring criminal property, or removing it from the UK (Section 327 of the Act); entering into or becoming concerned in an arrangement that you know or suspect facilitates the acquisition, retention, use, or control of criminal property by or on behalf of another person (Section 328 of the Act); and acquiring, using, or possessing criminal property (Section 329 of the Act).

4. Responsibilities.

It is Aston Card Limited’s policy to ensure that our company, its management, and all of our company’s employees are committed to complying with all legislation and appropriate guidelines designed to combat money laundering activity, the funding of terrorist or criminal activity in the jurisdictions in which we operate. Aston Card Limited will:

Take reasonable steps to establish the identity of any person for whom it is proposed to provide any services where applicable.

Retain identification and transactional documentation as defined in the legislation in the jurisdiction in which we operate.

Provide initial and ongoing training to ensure all relevant staff are aware of their personal responsibilities and the anti-money laundering procedures in respect of identifying clients, monitoring, record-keeping, remaining vigilant at all times, and reporting suspicious transactions.

Ensure our Policy is developed and maintained in line with evolving statutory and regulatory obligations from enforcement agencies.

Report to the relevant authority where there are reasonable grounds to suspect that a money laundering offense has been committed.

We will at all times ensure the protection of our staff and safeguard our organization and reputation against the threat of money laundering and the funding of terrorist and criminal activities.

5. Risk Assessment.

Aston Card Limited is a supplier of financial services. Our services will be based on the following principles and markets:

No financial transactions or money handling will be undertaken by Aston Card Limited, other than the charges made for the services outlined above.

Aston Card Limited does not offer any Banking, Accounting, or Secretarial services.

6. Risks, Vulnerability, and Due Diligence.

In order to transfer or process financial transactions, the user will have a bank account, which will be subject to the anti-money laundering regulations for that particular institution. For example, to open a bank account, it is now the normal procedure for the bank to ask for proof of identity, i.e., passport, utility bill, or similar.

In terms of the due diligence required by the anti-money laundering act, Aston Card Limited will take the following steps to identify the merchants:

Recognizing the True Identity of our Customers, perform the necessary KYC according to the law.

Aston Card Limited will hold any relevant data as described above on record, as required by the anti-money laundering act 2007, and will fully comply with the Data Protection Act.

Aston Card Limited will do all it can to prevent the company and its staff from being exposed to money laundering, identify the potential areas where it may occur, and comply with all legal and regulatory requirements, especially with regard to the reporting of actual or suspected cases.

7. Key Issues.

Aston Card Limited is committed to the prevention, detection, and reporting of money laundering. All employees must be vigilant for the signs of money laundering. Any employee who suspects money laundering activity must report this promptly to the Money Laundering Reporting Officer.

There are also two secondary offenses: failure to disclose any of the three primary offenses above, and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

Any member of staff could potentially be caught by the money laundering provisions if they suspect money laundering and either become involved with it in some way or do nothing about it. This Policy sets out how any concerns should be raised.

While the risk to Aston Card Limited of contravening the legislation is low, it is important that all employees are familiar with their responsibilities as serious criminal sanctions may be imposed for breaches of the legislation. The key requirement of employees is to promptly report any suspected money laundering activity to the Money Laundering Reporting Officer.

Last updated on the 15^th of October 2023.