AML Policy Statement

1. Our Legal Obligations

GW Pro Advisory Services Ltd is a regulated accountancy practice subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), the Proceeds of Crime Act 2002, and the Terrorism Act 2000. We take our obligations under these laws extremely seriously.

2. Risk-Based Approach

We adopt a risk-based approach to anti-money laundering compliance in accordance with HMRC guidance for accountancy service providers. We assess the risk posed by each client relationship and apply appropriate due diligence measures based on that assessment.

3. Customer Due Diligence (CDD)

Before providing services to any new client, we carry out Customer Due Diligence (CDD). This requires us to:

• Verify the identity of each client using official photographic identification (passport or driving licence)
• Verify the client's address using a recent utility bill, bank statement or similar document
• Understand the nature and purpose of the business relationship
• Assess the source of funds where relevant
• Screen clients against PEP (Politically Exposed Person) and sanctions lists

We may be required to conduct Enhanced Due Diligence (EDD) for higher-risk clients or situations, which involves gathering additional information about the client's circumstances and source of wealth.

4. Ongoing Monitoring

We conduct ongoing monitoring of client relationships and transactions throughout the engagement. We update client due diligence information periodically and whenever we become aware of material changes to a client's circumstances.

5. Reporting Obligations

We are legally required to report suspicions of money laundering or terrorist financing to the National Crime Agency (NCA) by submitting a Suspicious Activity Report (SAR). We are prohibited by law from informing clients or third parties that a report has been made or is being considered (tipping off). We cannot act on a client's instructions if we are waiting for consent from the NCA.

6. Record Keeping

We retain all customer due diligence records and supporting documents for a minimum of five years from the end of the client relationship, as required by the Money Laundering Regulations 2017.

7. Staff Training

All relevant staff receive appropriate AML training and are required to be aware of their obligations under the applicable legislation. Our MLRO is responsible for ensuring compliance with our AML procedures.

8. Policy Review

This policy is reviewed annually and updated as required to reflect changes in legislation, regulatory guidance, and best practice.