Anti money laundering policy
Centurion Legal intends to comply with the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002 and anti-terrorism laws.
We have firm anti-money laundering procedures in place to ensure compliance with the law. This also involves us verifying the identity of our clients and understanding how they are organised/structured.
Client and Matter Due Diligence
We conduct due diligence enquiries on all new clients to:-
- establish and verify our client’s identity; and
- ascertain the identity of any beneficial owners.
Even if you are not our direct client, we may need to identify you if you are providing us with instructions on our client’s behalf. We cannot act if sufficient information is not provided.
We conduct our due diligence via electronic checks online with third-party companies, but may also need to see original documentation.
We will normally have to carry out an enhanced due diligence check, if any of the following applies to you, as our client:-
- you are based outside of the European Union;
- you are a politically exposed person;
- if we need to meet you in person and you are unable to do so;
- if your business primarily operates in a country which does not have anti-money laundering legislation comparable to the United Kingdom;
- we cannot identify the source of any funds used to finance your transaction; and/or
- if you ask a third-party to make payments to us on your behalf.
The above is a non-exhaustive list and we review each case on an individual basis. When we use the phrase “you”, above, this applies to the individuals who control your business, being the directors and/or shareholders or any other relevant stakeholders.
Please do not be offended if we do ask you for further evidence to satisfy our checks, as they are both a legal and regulatory requirement.
In the event that you refuse to provide any documents which we reasonably request, or these documents do not satisfy our checks, we may not be able to act for you.
We also undertake risk assessments for all new matters for existing clients. This is to determine the degree of risk posed by the matter and if the identity and/or ownership of our client has materially changed.
We assess risk against the criteria as set out in the Solicitors’ Regulation Authority’s guide:-
We undertake on-going monitoring of all existing clients (which may require you to provide us with updated proof of your ID).
We must report to the National Crime Agency and other relevant authorities any suspicion or knowledge regarding money laundering or the proceeds of crime. We are not permitted to notify you of the fact that such reports have been made.
Our duties to report to the National Crime Agency may take priority over any duty to keep your information and the detail of your transactions confidential.