In common with other professional services firms, we are required by the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”) to:
We may use electronic checks as part of our identification and verification procedures.
These electronic checks are not credit checks.
We have a statutory obligation under the above legislation to report to the National Crime Agency (NCA) any knowledge or suspicion (or reasonable grounds for knowledge or suspicion) of money laundering or terrorist financing.
Any such report must be made in strict confidence. In fulfilling our legal obligations, neither the firm’s principals nor staff may enter into correspondence or discussions with you regarding such matters.
If we are unable to obtain satisfactory evidence of identity (and, where applicable, identity of beneficial owners and/or controlling persons), we will not be able to proceed with, or continue, the engagement.
If you undertake business that requires supervision by an appropriate supervisory authority for anti-money laundering compliance, you must inform us promptly. This includes where you accept or make high-value cash payments of €10,000 or more (or equivalent in any currency) in exchange for goods.
Any personal data received from you to comply with MLR 2017 obligations will be processed only for the purposes of preventing money laundering or terrorist financing, unless another lawful basis applies under applicable data protection or other legislation, or we have obtained valid consent where required.
You agree to provide all information and documents reasonably requested by us for AML/KYC purposes on a timely basis and to notify us promptly of any change to ownership, control, authorised signatories, or constitutional details relevant to verification.
The effective date of this clause is 24 July 2025.