1. Introduction

1.1 Purpose
The purpose of this Anti-Money Laundering (AML) policy is to establish and maintain effective measures to prevent Customer Solutions LTD from being used for money laundering or terrorist financing activities. This policy outlines the company's commitment to AML compliance and defines the procedures and controls to be followed.

1.2 Scope
This policy applies to all employees, contractors, and agents of Customer Solutions LTD involved in any financial transactions and operations conducted by the company.

2. AML Compliance Officer

The AML Compliance Officer is responsible for overseeing and implementing this policy. Their responsibilities include:

• Monitoring and ensuring compliance with AML laws and regulations in the United Kingdom.
• Reporting suspicious activities to the appropriate authorities, in the United Kingdom, the Financial Conduct Authority.
• Conducting risk assessments and updating AML procedures as necessary.
• Providing AML training and guidance to employees.
• Serving as the point of contact for AML-related matters.

3. Customer Due Diligence (CDD)

3.1 Identification and Verification
Customer Solutions LTD will implement robust CDD procedures to identify and verify the identity of customers, including beneficial owners. This includes obtaining relevant documents, such as government-issued IDs and proof of address, for all payers with accumulated transactions volume above 1000 EUR or equivalent in different currency.

3.2 Ongoing Monitoring
The company will continuously monitor customer transactions and account activity for suspicious behavior and ensure that customer information is up-to-date.

3.3 Enhanced Due Diligence (EDD)
For high-risk customers or transactions, enhanced due diligence measures will be applied, which may include additional documentation and scrutiny.

3.4 Politically Exposed Persons (PEPs)
The company will identify and screen politically exposed persons and apply enhanced due diligence procedures when dealing with them.

4. Reporting Suspicious Activity

4.1 Suspicion Indicators
Employees must be vigilant for signs of suspicious activity, including unusual transactions, inconsistent information, or other red flags.

4.2 Reporting Procedures
Any suspicions of money laundering or terrorist financing must be promptly reported to the AML Compliance Officer, who will then take appropriate action, including filing reports with the relevant authorities.

5. Record Keeping

5.1 Document Retention
All AML-related documents, records, and reports will be retained for the legally mandated period.

5.2 Data Protection
Customer information and AML records will be protected in accordance with data protection laws and company policies.

6. Employee Training

6.1 AML Training Program
All employees will undergo AML training to ensure they understand their responsibilities and are aware of AML laws and regulations.

6.2 Regular Updates
Employees will receive ongoing training and updates to stay current with evolving AML risks and regulations.

7. AML Risk Assessment

7.1 Risk Categories
Customer Solutions LTD will categorize and assess AML risks associated with its business activities, customers, and geographical locations.

7.2 Risk Assessment Process
The company will regularly assess AML risks and adjust its AML procedures accordingly.

8. AML Audit and Review

8.1 Independent Audit
An independent audit of AML procedures and controls will be conducted periodically to ensure compliance.

8.2 Policy Review
This policy will be reviewed and updated as necessary to reflect changes in AML laws and regulations.

9. Penalties for Non-Compliance

Non-compliance with this AML policy may result in disciplinary action, including termination of employment or legal action, as well as fines or penalties against the company.