Anti-Money Laundering Policy

1. Introduction

Compare Your Funding is the trading style of TGL Solutions Limited. TGL Solutions Limited is a UK-registered company providing non-regulated credit brokering facilities. The business is considered medium risk in relation to money laundering due to dealings with some cash-intensive businesses. To prevent our services from being used (or potentially used) for any money laundering activity, and to protect our staff from exposure to money laundering, we have put in place the following Anti-Money Laundering Policy.

2. Scope of the Policy

The broad definition of money laundering means that potentially anyone could commit a money laundering offence. This includes all employees of the company, all temporary staff, and contractors.

Our policy enables the company to meet its legal and regulatory requirements in a way that is proportionate to the medium-risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring. All employees must be familiar with their legal responsibilities.

3. What is Money Laundering?

The Proceeds of Crime Act 2002 (POCA 2002) consolidated, updated, and reformed criminal law regarding money laundering.

Money laundering can be defined as the process of moving illegally acquired cash through financial systems so that it appears to originate from a legitimate source. Money laundering offences include:

• Concealing, disguising, converting, transferring criminal property, or removing it from the UK (Section 327 POCA)
• Entering or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use, or control of criminal property by or on behalf of another person (Section 328 POCA)
• Acquiring, using, or possessing criminal property (Section 329 POCA)

There are also several secondary offences:

• Failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO)
• Failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency (NCA)
• 'Tipping off' – whereby somebody informs a person or persons who are, or are suspected of being, involved in money laundering in such a way as to reduce the likelihood of their being investigated or to prejudice an investigation

Any member of staff could potentially be caught by the money laundering provisions if they suspect money laundering and either become involved in it in some way and/or fail to act. This policy sets out how any concerns should be raised.

4. Money Laundering Reporting Officer (MLRO)

The company will appoint a Money Laundering Reporting Officer (MLRO) to receive disclosures about money laundering activity and to be responsible for anti-money laundering activity within the company. The nominated officer for this role is Stuart Hagan.

The MLRO will ensure that appropriate training and awareness is provided for new and existing employees, and that this is reviewed and updated as required. The MLRO will also ensure that appropriate anti-money laundering systems and processes are incorporated by the company.

5. Suspicions of Money Laundering

All employees must promptly report any suspicious activity to the MLRO using the prescribed form set out in this policy document.

Once the matter has been reported to the MLRO, the employee must follow the directions given to them and must NOT:

• Make any further enquiry into the matter
• Voice any suspicions to the person(s) whom they suspect of money laundering, as this may constitute the offence of 'tipping off'
• Discuss the matter with others
• Note on the file that a report has been made to the MLRO, in case this results in the suspect becoming aware of the situation

6. Consideration of the Disclosure by the MLRO

Once the MLRO has received the report, it must be evaluated in a timely manner to determine whether:

• There is actual or suspected money laundering taking place; or
• There are reasonable grounds to know or suspect that this is the case
• Whether the MLRO needs to lodge a Suspicious Activity Report (SAR) with the National Crime Agency (NCA)

Where the MLRO concludes that there are no reasonable grounds to suspect money laundering, consent will be given for any ongoing or imminent transaction(s) to proceed.

Where consent is required from the NCA for a transaction to proceed, the transaction(s) in question must not be undertaken or completed until the NCA has given specific consent, or there is deemed consent through the expiration of the relevant time limits without objection from the NCA.

All disclosure reports made to the MLRO, and any reports made to the NCA will be retained by the MLRO in a confidential file kept for that purpose, for a minimum of five years. The MLRO must also consider whether additional notifications and reports to other relevant enforcement agencies should be made.

7. Customer Identification and Due Diligence

Due diligence is performed on all potential clients, who must provide basic information including name, address, registration details, accounts, website, bank statements, photo ID, and proof of address.

For instructions from new customers or customers not well known to the company, customers in known high-risk industries and/or jurisdictions, transactions that are unusual for the customer, or other unusual requests, and highly complex transactions or payment arrangements, the company may seek additional evidence of identity. This may include:

• Checking the organisation's website to confirm the identity of personnel, its business address, and any other relevant details
• Visiting the customer at their business address
• Conducting internet searches
• Evidence of the personal identity of the key contact (passport, photograph, or driving licence)

If satisfactory evidence of identity is not obtained at the outset, the business relationship or one-off transaction(s) cannot proceed any further.

8. Record Keeping

Where 'relevant business' is carried out, the customer identification evidence and details of the relevant transaction(s) for that customer must be retained for at least six years.