Anti-Money Laundering Policy 

1. Purpose

1.1 Owen Reed Limited (“the Company”) is committed to the highest standards of regulatory and ethical conduct and seeks to comply with all laws and regulations applicable to its operations, including but not limited to those related to anti-money laundering (AML).

1.2 The Company is dedicated to preventing, detecting, and reporting money laundering activities and ensuring that its services are not used to facilitate money laundering or the financing of terrorist activities.

2. Money Laundering

2.1 Money laundering is defined as the process of making illegally-gained proceeds (i.e., "dirty money") appear legal (i.e., "clean"). This typically involves three steps: placement, layering, and integration.

2.2 The Company recognises the importance of preventing money laundering and terrorist financing and commits to taking appropriate measures to identify, mitigate, and manage these risks.

3. Consequences of Non-Compliance

3.1 Non-compliance with AML laws and regulations can lead to severe penalties, including fines, imprisonment, and damage to the Company's reputation.

3.2 Employees found to be in violation of this Policy may face disciplinary action, up to and including termination of employment.

3.3 The Company itself may face legal sanctions, financial penalties, and reputational harm if it is found to have facilitated money laundering or terrorist financing activities.

4. Responsibility for Compliance and Scope of Policy

4.1 This Policy applies to all employees, officers, directors, agents, and anyone else acting on behalf of the Company.

4.2 All parties are required to comply with this Policy, undertake due diligence to prevent, identify, and report potential money laundering activities, and attend regular training on AML regulations and practices.

4.3 Employees are required to report any suspicious activities or transactions that may involve money laundering or terrorist financing to the designated AML Compliance Officer.

5. Due Diligence

5.1 The Company will conduct due diligence on all clients, customers, and transactions to identify and mitigate the risks associated with money laundering and terrorist financing.

5.2 Enhanced due diligence will be performed on high-risk customers and in high-risk situations as identified by the Company’s risk assessment procedures.

6. Reporting Suspicious Activity

6.1 Employees are required to immediately report any suspected money laundering or terrorist financing activities to the AML Compliance Officer.

6.2 The AML Compliance Officer is responsible for evaluating such reports and, if necessary, filing Suspicious Activity Reports (SARs) with the appropriate authorities.

7. Record Keeping

7.1 The Company will maintain all records related to financial transactions and customer identification for a minimum period as required by law.

7.2 These records will be available for inspection by relevant authorities upon request.

8. Training

8.1 The Company will provide regular training on AML laws, regulations, and policies to all employees and relevant parties.

8.2 The training will include information on recognising and reporting suspicious activities and understanding the legal obligations related to money laundering and terrorist financing.

9. Review and Monitoring

9.1 The Company will regularly review and update this Policy to ensure compliance with evolving AML laws and regulations.

9.2 Continuous monitoring will be conducted to ensure the effectiveness of the AML measures and procedures.

This policy has been approved & authorised by:

Name: Sebastian Pampanini

Position: Operations Director

Date: 29 February 2024N