Anti Money Laundering Policy

Introduction

At Towcester Family Law Practice we are committed to protecting our clients from fraudulent use of their names and addresses by criminals for money laundering purposes.  This applies to both new clients and existing clients.

Money laundering is a financial crime that enables criminals to disguise the source of their money.  The result is that ‘dirty’ money appears ‘clean’ and it is then reintroduced it into the banking system, making it harder to detect and confiscate. This money is often used to fund further crimes. Often, laundered money is used to finance the operation of criminal organisations, and activities including but not limited to, general fraud, drug trafficking, terrorist financing, theft and embezzlement, tax evasion and benefit fraud.

The first step in the laundering process is for criminals to get their money into an account with a bank or building society, often using a false identity and address.

In order to stop this, we must have proof of identity and proof of your address from you before you instruct us. We must also have proof of identity and proof of address from anyone who pays money to us on your behalf, before any money can be accepted.

This does not mean that we suspect you or anyone intending to pay money on your behalf of money laundering, but we are required by law to have evidence to show that you are who you say you are and that you live at the address you say you do.

These procedures ensure we are not only complying with the law, but are also doing our best to protect all of our clients.

Proof of Identity

Under the Proceeds of Crime Act 2002 and so that we can confirm your identity, we must check your identity against one of the items from list A or two documents from list B below:

List A            

1. Valid passport; or
2. Valid H M Forces identity card with photograph; or
3. Valid UK photocard driving licence

List B

1. Cheque guarantee card, credit card (bearing the Mastercard or Visa logo) American Express or Diners Club Card, debit or multi-function card (bearing the Switch or Delta logo) issued in the UK with the original account statement less than three months old; or
2. A firearm or shot gun certificate; or
3. A receipted utility bill, less than three months old; or
4. A council tax bill, less than three months old; or
5. A Council rent book showing the rent paid for the last three months;
6. A mortgage statement for the mortgage account year just ended.

Do not worry if you do not have any of the items listed above. Although the law does require us to have satisfactory proof of your identity and address, we do have alternative procedures for clients who have reasonable grounds for not being able to produce any of the above.

Occasionally, to comply with Bank of England sanctions and guidelines on money laundering, there may be additional checks and documents required if you are a national of or resident in certain countries.

Identification checks:

• Cash: We are normally only able to accept cash up to a limit of £500.00 in any 28 day period.

• Source of funds:  At the start of any matter, we will normally ask you to tell us the source of any funds you will be using.  It is simplest for us if the source is an account, in your name, in a UK bank or building society.  If the source is an unusual one, such as an account in another country, or in the name of someone other than yourself, please tell us as early as possible, including the reason. 

• Destination of funds:  Where we are to pay money out to you, we will normally do so by bank transfer to an account in your name or by cheque in your favour.  If you want us to pay money to someone other than yourself, please tell us in writing as early as possible, including the reason.

Confidentiality

We have always sought to keep our clients’ affairs confidential.  However the Proceeds of Crime Act 2002 can oblige us to report information about financial offences to the National Criminal Intelligence Service.  In particular, if it seems that any assets involved in your matter were derived from a crime we may have to report it.  This can include even small amounts of money, and covers all offences, including for example tax evasion and benefit fraud.  If we have to make a report we may not be able to tell you that we have done so.  A report may result in an investigation by the police, the Inland Revenue or other authorities.

If you require more information about our Money Laundering Policy please contact our Money Laundering Compliance Officer Heather Rose   [email protected]