Anti-Money Laundering (AML) Policy

1. Introduction

ShopMovies.co.uk (hereinafter referred to as Shopmovies Limited) is committed to preventing money laundering, terrorist financing, and other financial crimes. This AML policy outlines the procedures and measures implemented to ensure compliance with applicable laws and regulations, including but not limited to the UK’s Proceeds of Crime Act 2002, the Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017, and guidelines provided by Flutterwave.

Know Your Customer (KYC) Policy

2. Objectives

The primary objectives of this AML policy are to:

  • Prevent the use of the Company’s platform for money laundering or terrorist financing activities.
  • Establish procedures for identifying, monitoring, and reporting suspicious activities.
  • Ensure compliance with relevant laws, regulations, and industry best practices.
  • Protect the integrity of ShopMovies.co.uk and its stakeholders.

3. Roles and Responsibilities

  • Compliance Officer:
    The Company will appoint a Compliance Officer responsible for:
    • Implementing and overseeing the AML policy.
    • Training employees on AML procedures.
    • Monitoring transactions and identifying suspicious activities.
    • Reporting suspicious activities to relevant authorities.
    • Liaising with Flutterwave and regulatory bodies.
  • All Employees and Vendors:
    • Must comply with this AML policy.
    • Must report any suspicious activity to the Compliance Officer.

4. Customer Due Diligence (CDD)

The Company will perform Customer Due Diligence (CDD) on all users, vendors, and third parties using the platform.

4.1. Vendor Verification

Vendors registering on the platform will be required to provide:

  • Full name or registered business name.
  • Contact information (email and phone number).
  • Proof of identity (e.g., passport, driver’s license, or national ID).
  • Proof of address (e.g., utility bill or bank statement).
  • Business registration documents (if applicable).

4.2. Buyer Verification

( If any suspicious activities )

Buyers making transactions above a specified threshold will be required to provide:

  • Full name.
  • Proof of identity.
  • Payment method verification.

4.3. Risk-Based Approach

The Company will adopt a risk-based approach to assess the risk level of vendors and buyers, categorizing them as low, medium, or high risk based on factors such as:

  • Transaction amounts.
  • Geographic location.
  • Nature of the goods or services being traded.

5. Monitoring and Reporting Transactions

The Company will monitor all transactions to identify suspicious activities. Suspicious activities may include, but are not limited to:

  • Large or unusual transactions that do not match the customer’s profile.
  • Transactions involving high-risk countries identified by the Financial Action Task Force (FATF).
  • Multiple small transactions designed to avoid reporting thresholds.

5.1. Reporting Suspicious Activities

Suspicious transactions will be reported to:

  • The Compliance Officer for internal review.
  • The UK’s National Crime Agency (NCA) via a Suspicious Activity Report (SAR), if deemed necessary.

6. Record-Keeping

The Company will maintain records of:

  • Customer identification documents.
  • Transaction histories.
  • Suspicious Activity Reports (SARs).

All records will be kept for a minimum of five (5) years from the date of the transaction or the end of the customer relationship.

7. Employee and Vendor Training

The Company will provide training to employees and vendors on AML procedures, including:

  • Recognizing signs of money laundering and terrorist financing.
  • Understanding their responsibilities under this AML policy.
  • Reporting suspicious activities.

Training will be conducted annually or as required by changes in regulations.