Anti-Money Laundering (AML) Policy

Integrity Domiciliary Care Services (IDCS) Limited
Effective Date: August 2025
Next Review Date: August 2026

1. Policy Statement

Integrity Domiciliary Care Services (IDCS) Limited is committed to full compliance with all applicable UK anti-money laundering laws and regulations, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended. IDCS adopts a zero-tolerance approach to criminal activity, including money laundering, and implements appropriate measures to prevent its facilitation through our operations.

2. Purpose

The purpose of this policy is to:

• Prevent IDCS from being used to facilitate money laundering or terrorist financing

• Establish clear responsibilities and procedures for identifying and reporting suspicious activity

• Ensure all employees and contractors understand their roles in AML compliance

• Promote a culture of compliance, integrity, and ethical business practice

3. Scope

This policy applies to all IDCS staff, contractors, management, and any individuals or entities conducting business on behalf of the organisation. It applies to all operational areas, including:

• Employment and recruitment services

• Bookkeeping, payroll, and outsourcing activities

• Financial transactions involving third parties

• International invoicing or remittance (where applicable)

4. Legal Framework

IDCS complies with relevant legislation and guidance, including but not limited to:

• Proceeds of Crime Act 2002 (POCA)

• Terrorism Act 2000

• Money Laundering Regulations 2017

• The Joint Money Laundering Steering Group (JMLSG) guidance

• National Crime Agency (NCA) requirements

5. Definition of Money Laundering

Money laundering refers to the process by which criminals disguise the original ownership and control of the proceeds of criminal conduct by making such proceeds appear to be from a legitimate source. This includes:

• Concealing or transferring criminal property

• Entering into arrangements to facilitate the acquisition or control of criminal property

• Acquiring, using, or possessing criminal property

6. Responsibilities

6.1 Senior Management

• Ensure effective systems and controls are in place to prevent money laundering

• Promote AML awareness and training across the business

6.2 Money Laundering Reporting Officer (MLRO)

• Appointed MLRO: [To be Inserted – e.g., Sarah Santeng or delegate]

• Acts as the key point of contact for all AML matters

• Receives and assesses internal suspicious activity reports (SARs)

• Submits SARs to the National Crime Agency (NCA) when appropriate

• Maintains AML risk assessments and ensures regular review of controls

6.3 All Staff

• Remain alert to the risk of money laundering

• Comply with customer due diligence and record-keeping requirements

• Promptly report any suspicions to the MLRO

• Complete mandatory AML training

7. Customer Due Diligence (CDD)

CDD must be carried out before entering any business relationship or transaction. This includes:

• Verifying the identity of the client or service user

• Understanding the nature and purpose of the relationship

• Identifying the source of funds, where relevant

• Enhanced Due Diligence (EDD) for higher-risk clients (e.g. foreign entities)

Acceptable identification includes a government-issued photo ID (e.g. passport or driving licence) and proof of address.

8. Record-Keeping

IDCS will retain all AML-related records for a minimum of five years, including:

• Client identification documents

• Records of transactions

• Suspicious activity reports (SARs)

• Staff training logs

9. Suspicious Activity Reporting

All employees must report suspicious activity to the MLRO. Examples of suspicious behaviour include:

• Unusual or inconsistent payment methods

• Reluctance to provide ID

• Complex or unnecessary financial arrangements

• Transactions that appear to lack a legitimate purpose

The MLRO will assess the report and, if appropriate, submit a Suspicious Activity Report to the National Crime Agency (NCA).

10. Staff Training

IDCS will provide AML training to all relevant staff upon induction and at regular intervals. Training will cover:

• AML legislation and regulatory obligations

• Recognising suspicious transactions

• Internal procedures for reporting concerns

• The role of the MLRO

11. Breaches and Non-Compliance

Any employee who fails to comply with this policy may face disciplinary action, which may include dismissal. Serious breaches may be reported to the appropriate regulatory and legal authorities.

12. Review and Approval

This policy will be reviewed annually or following any significant changes in legislation or the structure of IDCS.

Approved by: Sarah Santeng
Position: Chief Executive Director
Date: August 2025