Anti-Money Laundering Policy

WiseWood Digital is committed to observing the provisions of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, Part 7 – Money Laundering Offences and the Terrorism Act 2000 (as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2013) in all of its affairs.  This policy aims to ensure that WiseWood Digital and all its employees comply with the legislation and that due diligence is applied in relation to ‘know your customer’ principles.

This policy sets out the procedure to be followed if money laundering is suspected and defines the responsibility of individual employees in the process.

WiseWood Digital has a zero-tolerance policy towards money laundering, and is committed to the highest level of openness, integrity and accountability, both in letter and in spirit. The penalties for these offences are severe and can mean up to 14 years imprisonment and/or an unlimited fine for the employees and executives responsible. In addition, there would be significant reputational damage for WiseWood Digital.

This policy applies to all staff of the Company and its subsidiary companies and applies to all income and expenditure. Any breach of this policy will be a serious matter, may result in disciplinary action and could result in an employee becoming personally liable to criminal prosecution.

Customer due diligence when establishing a business relationship

A business relationship is one that you enter into with a customer where both of you expect that the relationship will be ongoing. It can be a formal or an informal arrangement.

When we establish a new business relationship we need to obtain information on:

  • the purpose of the relationship
  • the intended nature of the relationship – for example where funds will come from, the purpose of transactions, and so on

The type of information that you need to obtain may include:

  • details of your customer’s business or employment
  • the source and origin of funds that your customer will be using in the relationship
  • band and trade references
  • Companies House search
  • details of the relationships between signatories and any underlying beneficial owners
  • the expected level and type of activity that will take place in your relationship