Anti-Money Laundering and
Counter-Terrorism Financing Policy
For Genosumi Limited and EU Subsidiary

October 2018

Though Genosumi Limited business operations are outside the regulated sector for Money Laundering, Terrorist Financing and Transfer of Fund regulations 2017 and does not have the reporting obligations of regulated companies, nevertheless as a non-regulated business, we do face the risk of liability for substantive money laundering or terrorist financing offence, and the duty under the Terrorism Act 2000 to report beliefs or suspicions that arise in the course of our business tradings.

As such the company is of the opinion that it will be good business practice to embrace the legislation and implement it within its organisation. So the Company is putting in place internal guidelines and procedures to prevent the use of the operations of the company trading activities for Money Laundering purposes and to report any incidents of money laundering to the appropriate and relevant authorities as soon as it becomes aware of such incidents.

Also as Genosumi is the parent company of an EU overseas subsidiary, our policies, controls and procedures will also be extended to apply to this subsidiary company whose business operations, like us, are outside the regulated sector.
Not all of our businesses, as well as that of our subsidiary, is relevant for the purposes of the legislation.

The Money Laundering Regulations require that an organisation has a Nominated Officer to ensure that there is up-to-date knowledge of issues relating to Anti-Money Laundering and Counter-Terrorist Financing throughout the organisation, implement appropriate policies and procedures and receive reports of suspicious activity.

The Nominated Officer (Money Laundering Reporting Officer (MLRO)) for Genosumi and its subsidiary is Mr Steven Kemp and in the absence or sickness of the MLRO, Martin Dushkaj will be the deputy/assistant MLRO.

This policy applies to all employees regardless of nationality and location of employment working for the company and its EU subsidiary.

Our Internal Procedures, including internal control and guidelines are based on those recommended by the Money Laundering regulation.

So the company and its EU subsidiary have established appropriate and risk-sensitive policies and procedures relating to:

  • Customer due diligence
  • Reporting suspicions of money laundering
  • Record-keeping
  • Risk assessment and management
  • Training

Money laundering is the process through which proceeds of crime and their true origin and ownership are changed so that the proceeds appear legitimate. Terrorist financing is providing or collecting funds, from legitimate or illegitimate sources, to be used to carry out an act of terrorism.

The anti-money laundering (AML) and counter-terrorist financing (CTF) regime is designed to prevent the use of the operations of the company and its subsidiary trading activities being used by criminals. You have obligations under the AML/CTF regime to spot and report money laundering and terrorist financing. Failure to meet these obligations can lead to criminal penalties, substantial fines and untold damage to your own and Genosumi and its subsidiary reputation.

Typically money laundering involves three stages:


The process of placing criminal property into the financial system. This might be done by breaking up large sums of cash into smaller amounts or by using a series of financial instruments (such as cheques or money orders) which are deposited at different locations.


The process of moving money that has been placed in the financial system in order to obscure its criminal origin. This is usually achieved through multiple complex transactions often involving complicated offshore company structures and trusts.


Once the origin of the money is disguised it ultimately must reappear in the financial system as legitimate funds. This process involves investing the money in legitimate businesses and other investments such as property purchases or setting up trusts.

We are most likely to become involved in the layering stage but potentially could be involved in any stage.

You do not have to behave like a police officer but you do have to remain alert to the warning signs of money laundering and terrorist financing and make the sort of enquiries that a reasonable person (with the same qualifications, knowledge and experience as you) would make.

Typical signs of money laundering and terrorist financing are:

Obstructive or secretive clients

Instructions outside our usual range of expertise, i.e. why is the client using us?

Clients based a long way from us with no apparent reason for using us

Cases or instructions that change unexpectedly or for no logical reason, especially where:

  • The client has deposited funds with us
  • The source of funds changes at the last moment
  • You are asked to return funds or send funds to a third party
  • Loss-making transactions where the loss is avoidable
  • Complex or unusually large transactions
  • Transactions with no apparent logical, economic or legal purpose
  • Large amounts of cash being used
  • Money transfers where there is a variation between the account holder and signatory
  • Payments to or from third parties where there is no logical connection to the client
  • Movement of funds between accounts, institutions or jurisdictions without reason
  • Retainers involving high risk jurisdictions (e.g. Iran, Uzbekistan, Turkmenistan, Pakistan, Sao Tome and Northern Cyprus)
  • Large payment on account of fees with instructions terminated shortly after and the client requesting the funds are returned

Criminals are always developing new techniques so this list can never be exhaustive.

All employees must report any suspicion or knowledge of money laundering to the MLRO immediately they become aware of such matters. Failure to do so will be a breach of this policy and is a criminal offence. If you are unsure whether an act amounts to money laundering, you should still raise your concerns with the MLRO.Any client activity outside the normal or expected activity should be considered unusual and must be investigated. Understanding the business or client profile is crucial. Unusual activity or transactions outside the established profile should be considered as a potential indicator of suspicious activity. Investigations should establish the reasons for the unusual activity or transaction. This may either remove or confirm your suspicion. If the MLRO gives you consent to proceed with a transaction, then that consent only applies to that specific transaction.

Reports received by the MLRO, or made by him to the NCA, will be treated confidentially and if made in good faith will not infringe any duty of client confidentiality or obligations under the Data Protection Act 2018.
In the absence or sickness of the MLRO, Martin Dushkaj will be the the deputy/assistant MLRO.

The Proceeds of Crime Act 2002 (POCA 2002) establishes a number of money laundering offences.

There are three principal offences and a third party offence relating to the three principals.

The principal Offences are:

  • Conceal, disguise, convert, transfer or remove criminal property from the UK (s327)/li>
  • Enter into or become concerned in an arrangement which facilitates the acquisition, retention, use or control of criminal property for or on behalf of another (s328), or
  • Acquire, use or have possession of criminal property (s 329)

The principal money laundering offences carry a maximum penalty of 14 years' imprisonment, a fine or both. You will have a defence to a principal money laundering offence if you submit a Suspicious Activity Report (SAR) to Steve Kemp (MLRO).

Third party offences are:

Failure to make a SAR, where you have knowledge or suspicious of one of the three main principal offences above, being committed to the MLRO.

Tipping-off and prejudicing an investigation

Tipping off’ is a criminal offence punishable by imprisonment and is prohibited by this policy.

You will commit the tipping-off offence if you disclose to the person to whom the disclosure relates that you, or anyone else:

  • Has made an SAR to the Nominated Officer (or NCA)
  • Of information which came to you in the course of business
  • That disclosure is likely to prejudice any investigation that might be conducted following the SAR

Staff members must not discuss the fact that a report has been made or is about to be made with either the client or a third party except for immediate department members on a ‘need to know’ basis.

You will not commit tipping-off by discussing your concerns with or submitting a SAR to Steve Kemp (MLRO). A tipping off offence cannot be committed if a report has not been submitted and you liaise with clients or colleagues as part of your enquiries into an unusual activity. However, you cannot mention the word suspicious.

All these offences are punishable by up to five years' imprisonment, a fine or both.

Both POCA 2002 and TA 2000 run parallel to the Money Laundering Regulations 2007 (Amended 2012), which are explained below.

Under the Money Laundering Regulations 2017, the company is required to have systems and controls to forestall money laundering and terrorist financing requirement that you must perform client due diligence before you establish a business relationship and when you identify any factors relevant to your risk assessment that have changed. These include:

Client Due Diligence (CDD)

Before the company and its EU subsidiary, establish a business relationship and when we identify any factors relevant to our risk assessment that have changed, we must perform a Client Due Diligence (CDD) to:

  • Identifying and verifying the client's identity
  • Identifying the beneficial owner where this is not the client
  • Obtaining details of the purpose and intended nature of the business relationship
  • Conducting ongoing monitoring of the business relationship

Enhanced Due Diligence (EDD)

Also where the client/customer is a Government organisation, we must carry out Enhanced Due Diligence (EDD) on both the source of funds and all government officials who are appointed to deal with us directly. The EDD will involve additional measures to identify and verify the person’s identity and source of funds and doing additional ongoing monitoring.

In order to reduce any potential risk associated with politically exposed persons, all company staff must not deal with any family members or business associates of any Government official. If you are approached to do so, then you must contact Steve Kemp your (MLRO).

There are very limited circumstances in which this may not apply, e.g. we may be able to verify the client's identity during the establishment of a business relationship if this is necessary to avoid interrupting the normal course of business and there is little risk of money laundering--this is on condition that the verification is completed as soon as practicable after contact is first established.

You must never unilaterally decide that it is acceptable to delay completion of CDD or EDD. If you are unable to apply or complete CDD or EDD on any matter, you should immediately seek advice from Steven Kemp (MLRO).

Staff and company officials must be aware that where the company or its EU subsidiary has contracted-out all or part of its obligations in fulfilling a contract, there is no legal requirement under Money Laundering, for the subcontractor to report suspicious activity to Steven Kemp our MLRO.

However, where the subcontractor brings to our attention of information which gives rise to a money laundering suspicion, then the MLRO must consider it’s our reporting obligations.

So, it still remains our responsibility for compliance and for ensuring that we undertake CDD, and or EDD on our Customer.

It will be good practice for Steven Kemp (MLRO) to make the subcontractor aware of the company’s and its EU Subsidiary stance on the anti-money laundering regulation so that common standards can be observed by the subcontractor.

Although our business model does not meet the definition of High value dealers under the regulation, nevertheless due to the nature and environment of both the company’s and its EU subsidiary business operation and the type of customers who engage us, it is the company’s and its EU subsidiary company’s policy not to accept any cash payment, including when it is made into our bank, in settlement of services provided to the Customer.

You must understand the purpose and intended nature of the business relationship. This is a key part of both CDD and EDD process. It will enable you to perform your risk assessment of the client and retainer and help you to determine appropriate CDD and EDD measures.

Knowing more about the client and their normal activities will help you to spot something unusual.

A transaction which appears to serve no purpose could be a money laundering or terrorist financing warning flag.

What is ongoing monitoring?

Ongoing monitoring is an intrinsic part of the CDD and EDD process. It must be performed on all matters, regardless of their individual risk rating, in order to detect unusual or suspicious transactions.

How do I conduct ongoing monitoring?

You should:

  • Scrutinise transactions undertaken (including, where necessary, the source of funds) to ensure that the transactions are consistent with your knowledge of the client, their business and risk profile
  • Stay alert to changes in the client's risk profile and anything that gives rise to suspicion
  • Keep documents, data and information used for CDD or EDD purposes up to date

Who will receive training?

All relevant employees/company officials are trained on their responsibilities in relation to money laundering legislation, and are aware of how to identify and deal with transactions that may involve money laundering.

What does the training involve?

Training is provided through online courses.

It covers:

  • The law relating to money laundering and terrorist financing
  • Our policy and procedures
  • Guidance on detecting money laundering and terrorist financing

Is completion of training compulsory?

Completion of training is compulsory.

How often will training be provided?

All new joiners will receive training as part of the induction process. Further training will be provided as required.

The Nominated Officer will continually monitor training needs but if you feel that you need further training on any aspect of the relevant law or our AML policy and procedures, please contact Steve Kemp (MLRO)

How will compliance with this policy be monitored?

Compliance will be continually monitored through any or all of the following methods:

  • File audits
  • Review of records maintained by the Nominated Officer
  • Reports or feedback from staff
  • Any other method

What are the consequences for failing to comply?

Failure to comply puts both you and the organisation at risk. You may commit a criminal offence if you fail to comply with this policy. The AML and CTF regimes carry heavy criminal penalties ranging from two years' imprisonment for failing to apply appropriate CDD measures to 14 years' imprisonment for committing a principal money laundering or terrorist financing offence. We take compliance with this policy very seriously. Because of the importance of this policy, failure to comply with any requirement may lead to disciplinary action under our procedures, which may result in dismissal.

We will review this policy at least annually as part of our overall risk management process. We will also review this policy if:

  • There are any major changes in the law or practice
  • We identify or are alerted to a weakness in the policy
  • There are changes in the nature of our business, our clients or other changes which impact on this policy
You can get further advice and guidance from the Nominated Officer, Steve Kemp, or, in his absence the deputy Martin Dushkaj.