aml risk management wih policy and procedures 16 october 2013

8/12/2019 AML Risk Management Wih Policy and Procedures 16 October 2013

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M L R O / H e a d o f C o m p l i a n c e D e p a r t m e n tFatima Fernandes

ANTI-MONEY LAUNDERINGMANUAL

O c t o b e r 2 0 1 2


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CONTENTS

Page

1. Glossary of terms.3

2. Introduction....8

3. Policy statement9

4. Compliance management structure...9

5. Risk assessment......14

6. The Law.....26

7. CDD....37

8. SAR.46

9. Record Keeping.51

10. Policies and Procedures Annex I ................................................52

11. Forms Annex II.............................................................................75


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GLOSSARY OF TERMS

AFU Asset Freezing Unit which is a department within HM

Treasury responsible for the freezing of assets belonging

to sanctioned individuals.

AML Anti-Money Laundering

Beneficial Owner The individual who ultimately owns or controls the

customer or on whose behalf a transaction or activity is

being conducted.

Business Relationship A business, professional or commercial relationship

between a relevant person (i.e. someone to whom the

MLR 2007 apply) and a customer, which is expected by

the relevant person, at the time when the contact is

established, to have an element of duration.

Cash Notes, coins and travellers cheques in any currency.

Consent Permission given by SOCA, for the carrying out of any

action that would constitute a money laundering offence

in the absence of that permission (see section 10).

Criminal Conduct Conduct which constitutes an offence in any part of the

United Kingdom, or would constitute an offence in any

part of the United Kingdom if it occurred there.

Criminal Property Any money or other assets which constitutes a persons

benefit from crime.

Customer due diligence

(CDD)

Identifying and verifying the identity of the customer and

any beneficial owner of the customer, and obtaining

information on the purpose of intended nature of the

business relationship.

EEA European Economic AreaEnhanced due diligence Additional customer due diligence measure that must be

applied:

Where the customer has not been physically

present for identification purposes.

Where the customer is a Politically Exposed

Person or

In any other situation which by its nature can

present a higher risk of money laundering or

terrorist financing.


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FATF Financial Action Task Force.

Financial Sanctions

Target List

A consolidated list of targets listed by the United

Nations, European Union and United Kingdom under

legislation relating to current financial sanctions regimes.

It is maintained by the AFU.

FSA Financial Services Authority: statutory regulator of most

financial services providers under the Financial Services

and Markets Act 2000.

HMRC Her Majestys Revenue and Customs. Supervisory

authority for all MSB.

Identification Ascertaining the name of, and other relevant information

about, a customer or beneficial owner.

Internal Report A report made to the Nominated Officer or MLRO in a

business.

JMLSG Joint Money Laundering Steering Group: body

representing UK Trade Associations in the Financial

Services Industry and aiming to promote good anti-

money laundering practices and give relevant practical

guidance.

Money Laundering An act which: Constitutes an offence under s. 327, 328 or 329

of POCA or

Constitutes an attempt, conspiracy or indictment

to commit such an offence or

Constitutes aiding, abetting, counselling or

procuring the commission of such an offence or

Would constitute an offence specified above if

done in the United Kingdom. [POCA, s. 340 (11)]

A person also commits an offence of money laundering if

he enters into or becomes concerned in an arrangement

which facilitates the retention or control by or on behalf

of another person of terrorist property:

By concealment

By removal from the jurisdiction

By transfer to nominees or

In any other way.

[Terrorism Act, s. 18]


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MLR 2007 The Money Laundering Regulations 2007

MLRO Money Laundering Reporting Officer. This term is used

to describe the nominated officer appointed under

regulations 20 (2) (d), MLR 2007 and s331, POCA.

Money Service Business An undertaking which by way of business operates a

currency exchange office, transmits money (or any

representations of monetary value) by any means or

which cashes cheques which are made payable to

customers.

Nominated Officer A person in a firm or organisation nominated by the firm

or organisation to receive disclosures under Regulation

7 and s. 330 of POCA from others within the firm or

organisation who know or suspect that a person is

engaged in money laundering. Similar provisions apply

under the Terrorism Act.

Occasional transaction A transaction (carried out other than as part of a

business relationship) amounting to 15,000 euro or

more, whether the transaction is carried out in a single

operation or several operations that appear to be linked.

Ongoing monitoring of abusiness relationship

Scrutiny of transactions undertaken throughoutthe course of the relationship (including, where

necessary, the source of funds) to ensure that

the transactions are consistent with the relevant

persons knowledge of the customer, his

business and risk profile and

Keeping the documents, data or information

obtained for the purpose of applying customer

due diligence measures up to date.

OFAC US Treasury Office of Foreign Assets Control.

Administers and enforces economic and trade sanctions

based on US foreign policy and national security goals

against targeted foreign countries, terrorists and

international drug traffickers.

OFAC SDN List Collectively, individuals and companies that are

designated by OFAC are called "Specially Designated

Nationals" or "SDNs." OFAC publishes a SDN list.

POCA Proceeds of Crime Act 2002.


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Politically Exposed

Person (PEP)

An individual who is or has, at any time in the preceding

year, been entrusted with prominent public functions, or

an immediate family member of such an individual, or a

known close associate, of such persons.

Prejudicing an

Investigation

The making of any disclosure or falsifying, concealing, or

destroying, or being complicit in these, of any documents

that are relevant to a money laundering investigation.

Regulated Sector Persons and firms which are subject to Money

Laundering Regulations.

Regulation EC

1781/2006

European Union Wire Transfer Regulations. Obliges

payment service providers to send information on the

payer with every transfer made on their behalf.

SAR Suspicious activity report made to SOCA.

Senior Management The directors and senior managers (or equivalent), of a

firm who are responsible, either individually or

collectively, for management and supervision of the firms

business.

Senior Manager An individual, other than a director (or equivalent), who is

employed by the firm, and to whom the board (or

equivalent) or a member of the board, has givenresponsibility, either alone or jointly with others, for

management and supervision.

Simplified due diligence An exception to the obligation to apply the customer due

diligence measures for specified customers, e.g. financial

institutions subject to the Money Laundering Directive or

equivalent legislation and supervision. It is also available

for some categories of products and transactions which

may be provided by financial institutions.

SOCA Serious Organised Crime Agency

Supervisory Authority Bodies identified by MLR 2007 regulation 23 as being

empowered to supervise the compliance of relevant

businesses with the 2007 Regulations.

Terrorism Act (TA 2000) Terrorism Act 2000, as amended by the Anti-terrorism,

Crime and Security Act 2001.

Terrorist offences The terrorist offences relate to fundraising, using or

possessing terrorist funds, entering into funding

arrangements, money laundering, disclosing information


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relating to the commission of an offence (similar to

tipping off), or failing to make a disclosure in the

regulated sector. (ss 19 and 21A TA 2000 (as

amended)).

Terrorist Property Money or other property which is likely to be used

for the purposes of terrorism (including any

resources of a prescribed organisation) or

Proceeds of the commission of acts of terrorism

or

Proceeds of acts carried out for the purposes of

terrorism.

Proceeds of an act includes a reference to any

property which wholly or partly, and directly or indirectly,

represents the proceeds of the act (including payments

or other rewards in connection with its commission).

Resources includes any money or other property which

is applied or made available, or is to be applied or made

available, for use by the organisation. [Terrorism Act, s.14]

Tipping off A tipping-off offence is committed if a person knows or

suspects that a disclosure falling under POCA s 337 or

338 has been made, and he makes a disclosure which is

likely to prejudice any investigation which may be

conducted following the disclosure under s 337 or s 338.

[POCA, s 333A].

Transaction The provision of any advice by a business or individual to

a client by way of business, or the handling of the clients

finances by way of business. A transaction could be

simply operating across a clients account.

Verification Verifying the identity of a customer, by reference to

reliable, independent source documents, data or

information, or of a beneficial owner through carrying out

risk-based and adequate measures.


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INTRODUCTION

This manual is designed to be used by the employees of LCC TRANS SENDING LIMITED,

a company that belongs to the Small World Group, as a guide to the AML responsibilities of

both the company and the staff.

In particular, it contains the information which all members of staff need to be aware of in

order to prevent the business being used to launder the proceeds of crime or terrorist

financing. All members of staff are at risk of committing a criminal offence if they assist in a

criminal transaction by missing the warning signs.

At the heart of this document is the risk based approach (see below). The risk-based

approach means that we focus our resources on the areas of greatest risk.

The possibility of being used to assist with money laundering and terrorist financing poses

many risks for our company including:

1. criminal and disciplinary sanctions

2. civil action against the firm as a whole and individual directors

3. damage to reputation leading to a loss of business

These risks must be identified, assessed and mitigated. If we know our customers well and

understand their instructions thoroughly, we will be better placed to assess risks and spot

suspicious activities. We will always start from the premise that most of our customers are

not launderers or terrorist financers but we must assess the risk level particular to our firm

and implement reasonable and considered controls to minimise those risks.

No matter how thorough our risk assessment or how appropriate our controls, some

criminals may still succeed in exploiting us for criminal purposes. But an effective, risk-based

approach and documented, risk-based judgments on individual customers will enable us to

justify our position on managing the risk to law enforcement, courts, HMRC and FSA.


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POLICY STATEMENT

The Directors are committed to operating the business in a transparent and open manner

consistent with their regulatory obligations. The directors and MLRO will always ensure that

all suspicious activity is reported to the authorities.

As part of this commitment LCC TRANS SENDING LTD will adopt strict compliance of all

applicable AML rules and regulations with specific emphasis on POCA, the 2007MLR and

EU Payment Services Directive 2009.

LCC TRANS SENDING LTD is aware that MSB have in the past been targets of organised

crime seeking to launder the proceeds of illicit activity. LCC TRANS SENDING LTD will

always seek to disrupt this activity by cooperating fully with the authorities and reporting all

suspicious activity to SOCA.

All staff must take steps to ensure compliance with this policy and ensure that they fully

understand the material contained in this manual.

It is the policy of LCC TRANS SENDING LTD that staff must receive AML training on

commencement of their duties. Staff will be given a copy of this manual and will be tested on

its contents before starting any client facing duties. The MLRO holds copies of all training

materials. Updated AML training is given annually. Records of all training including dates

delivered and by whom are kept both centrally and on staff personnel files.

The MLRO of LCC TRANS SENDING LTD is Fatima Fernandes. Her deputy is Seanna

Manita. All issues relating to SAR must be referred to Fatima in the first instance. The

compliance director of LCC TRANS SENDING LTD is Nicholas Day.

A copy of this manual will be provided to all LCCs subsidiaries, EEA Branches and all

directors, staff and agents.


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ROLES AND RESPONSABILITIES

Senior Management

Responsible for overall compliance policy of LCC TRANS SENDING LTD and ensuring

adequate resources are provided for the proper training of staff and the implementing of risk

systems. This includes computer software to assist in oversight. Senior management will be

sent monthly updates by the MLRO on compliance. They will also receive and consider the

annual MLRO report and implement any recommendations made within it. Assistance may

be given to the MLRO in the preparation of the AML manual.

MLRO

Responsible for receiving internal disclosures and making reports to SOCA. First point of

contact for all compliance issues from staff. Prepares annual report for consideration of

senior management and conducts risk assessments of compliance systems. Undertakes

regular random analysis of transactions including assessment of documentary evidence

provided by customers. Visits agents and overseas branches to ensure compliance with

group strategy. Assists in making any necessary amendments to AML manual in line with

increase/decrease in risk. Considers all compliance issues for group undertakings including

daily consideration of compliance forms.

Staff

Responsible for considering the AML manual and understanding responsibilities. Ensure

company procedures adhered to and obtain all documentary evidence as outlined within

manual. Ensure that all suspicious circumstances are reported to MLRO.

LCC TRANS SENDING LTD BUSINESS PROFILE

LCC TRANS SENDING LTD is an authorise Payment Institution licensed by FSA (Financial

Service Authority) FRN 504482, and currently we have EEA Branches in Belgium;

Netherlands, Luxembourg, Germany, Ireland, Italy, Portugal and France We provide in the

UK money transfer, bureau of change and cheque cashing facilities to all members of the

public.


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LCC Trans Sending is authorised to provide payment services of money remittance underPSD Outward Service to Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark,Estonia, Finland, France, Germany, Gibraltar, Greece, Hungary, Iceland, Ireland, Italy,Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal,Romania, Slovak Republic, Slovenia, Spain and Sweden.

ANTI MONEY LAUNDERING SYSTEMS AND CONTROLS

Under the MLR 2007 we are required to establish appropriate risk-sensitive policies and

procedures in order to prevent activities related to money laundering and terrorist financing

including those policies and procedures, which provide for:

Identification and scrutiny of complex or unusually large transactions, unusual

patterns of transactions with no apparent economic or lawful purpose and otheractivities regarded by the regulated person as likely to be of the nature of money

laundering or terrorist financing;

Prevention of use of products favouring anonymity;

Determination of whether a client is a PEP, using the Bridger Insight Platform

which screens all customers and beneficiaries names against PEPs

databases worldwide;

Customer due diligence i.e. procedures designed to acquire knowledge about our

customers and to verify their identity, as well as monitor business relationships and

transactions before executing the remittances;

Internal reporting including the appointment of a MLRO to receive the money

laundering reports required under POCA and the TA 2000 and a system for making

those reports;

Record keeping, including details of customer due diligence and supporting evidence

for business relationships, which need to be kept for five years after the end of a

relationship and records of transactions, which also need to be kept for f ive years;

Internal control, risk assessment and management, compliance monitoring,

management and communication; and


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than 900 per month. In addition to this the MLRO will undertake random monthly

checks upon customer accounts and provide a report to the compliance director on

her findings.

We must also keep up to date the information collected in applying CDD measures.

All ID will be retaken on the expiry of any documents used to verify customers.

Customer accounts will be placed on hold until the relevant CDD checks have been

undertaken or documents provided.

We must apply CDD measures at appropriate times to existing clients on a risk-

sensitive basis. The MLRO will assess the existing CDD database to identify those

customers that may require further/updated CDD checks.

We must apply EDD where the customer is another PI or SPI and ongoing and

monitoring transactions are applied. The MLRO will visit the MSB to ensure that they

are carrying out CDD and checking the relevant records for specific transactions.

In compliance with the Data Protection Act, when the customer is another MSB we

do not request full information from their customer, just the full name of the

customer, amount, recipient name and country and the unique reference number ofeach transaction. However the PI or SPI must be prepared to disclose any

information if required by us. In addition to this, for transactions more than

10.000.00, the proof of source of funds from the MSBs customer is required. Also

we conduct due diligences on the MSB before starting a relationship with them to

certify that the MSB carries out appropriate Customer Due Diligence. Where the

customer is a money transmission business we check if they are registered with the

Financial Services Authority (FSA) and HMRC. If they are not registered we will not

accept the customer.

We must apply EDD on third party payments. LCC only accepts Third Party

Payments for Countries that are not considered high risk jurisdictions by FATF and

OFAC and when the beneficial owner is identified.

We apply EDD on the overseas recipient requesting the proof of payment such as

invoices and checking if they are genuine.


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When the customer is a corporate customer, we apply EDD before starting

the relationship with the customer. We will check the companys and

Directors names on sanctioned lists, Safe Credit website, directors

disqualified list, the purpose to send the transaction, the annual turnover, the

list of customers beneficiaries and the relationship with the them,

beneficiaries names on FATF/OFAC lists and other sanctioned lists. We will

also define limits of amounts a corporate customer can send in a given

period.

When an overseas customer wants to carry out a transfer of funds to a

beneficiary in the UK, we treat him as a UK customer and must be identified

by our subsidiaries or correspondents while the beneficiary will be identified inthe destination country. The very same procedures of identification from LCC

will apply.

We provide payment services to agents subject to prior acceptance by us. To

comply with FSA requirement, we must obtain from the agent: name and

address of the agent, description of AML Internal controls mechanism (must

meet the LCC procedure), identification of directors and responsible persons,

and fit and proper test assessment. New agents will only start operating after

the authorisation from FSA is granted.

We have established internal procedures for investigating any complaint that

may be made against us in relation to any transaction. In accordance with

our complaints procedure, any complaint a customer may make relating to

any transaction must be made or confirmed to us in writing to Head of Client

Services at LCC Trans-Sending Ltd,168-170 Bermondsey Street, London SE1 3TQ

or by electronic message to [email protected]. We will

respond to the customer promptly. If the customer is still dissatisfied following

our response to any complaint, he has a right to refer the complaint

concerning the transaction to the Financial Ombudsman Service, South Quay

Plaza, 183 Marsh Wall, London E14 9SR.

In compliance with the communication dated 12 October 2009 from HM

Treasury on the Counter Terrorism Act 2008 (CTA), the company will notaccept any business relationship with (a) Islamic Republic of Iran Shipping

Lines (IRISL) and (b) Bank Mellat. The Company has checked all existing


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transactions to ensure no trading has been done with these concerns. We

have additionally blocked Bank Mellat and all their branches regardless the

location. Our business development department is aware of these measures.

In compliance with the communication daed 11 November 2011 from HM

Treasury, the company will not accept any business relationship and

transactions with all Iranian Banks, including their branches and subsidiaries

and the central bank of Iran.


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Local Compliance Structure LCC Trans-Sending Ltd.

SENIOR MANAGEMENTMr. Nicholas Day - Compliance Director

Mr. Christiano Simoes Business Development Director

Mr Rick Knox Commercial Director

STAFF

Lcc Trans Sending Ltd

MLRO Fatima Fernandes

EEA Branches nominate officersUK Fatima Fernandes

Ireland Mohammed RahmanBelgium Sofia Freitas

Portugal Paulo Sampaio Marques

Italy Luigi Del PrincipeGermany Daniel Kopelman

Luxembourg- Fatima FernandesNetherlands- Fatima Fernandes

France Fatima Fernandes

Subsidiaries: MLROUNO - Spain Javier Perez

SwissTransfers Switzerland - Christiano SimoesChoice Money Transfer USA Juan Gomez

SW Compliance team: 12 employees

Regulators

HMRC&FSA

FIU

COMPLIANCE TEAM

Equally liable for

enforcement action

SupervisorLcc Trans-Sending Ltd.

Report any suspicion ProvideTraining

to Staff

Make

Reports

Give

ConsentFull

Co-operation

Can take

enforcement

actionShareinformation

D

utytoprovideAMLtrainingandmater

ial

DutytoensureagherencetoAMLproce

dures


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OUR MONEY LAUNDERING RISKSAND WHAT WE WILL DO TO REDUCE THEM

Risk Explanation Triggers MCustomers It is important to have a

general understanding of the

risk profile of our customers

based on the type of

customers, purpose of

transactions, source and

destination of funds and the

expected value of frequency of

transactions. This will enable

the identification of unusual

transactions or patterns of

transactions without an

obviously economic or lawful

purpose, which could be

suspicious.

New customers that send less than

900 per calendar month,

Non face-to-face and customers who

are not local to the business that

carry out transactions larger than

900

New customers undertaking large

transactions.

Customers carrying out regular large

transactions.

Customers undertaking a number of

transactions below the amount

requiring ID in a short period of time.

A number of customers sending

We will r

name, d

address

relations

We will u

Diligenc

the profi

section.

Addition

of their a

departm

proceed

We will v

with ref

referred

section o


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payments to the same individual.

Other SPI or PI s Customers

Customers with complex ownership

structures with the potential to

conceal source of funds or underlying

beneficiaries.

Third Party Payments

Customers who are not local to the

business.

PEPs

Corporate Customers

who se

calenda

check w

sanction

Credit,

informat

electron

search p

be unde

be open

without

directors

monitore

All ID w

of expiry

This info

custome

MLRO

should b

Source

business


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risk tran

individua

9,000,

Complia

will be u

system

complian

All custo

5,000 p

provide

All custo

12,500

asked

occupat

All custo

professio

if they w

to be hig

Account

they wo


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they are

When th

SPI, th

identified

referenc

including

transact

PI or SP

On Thir

applied

institutio

If paym

invoice,

provided

checked

Product/transaction

types

Overseasremittances/money transfer

Overseas remittances can beused by criminals and

terrorists to move criminal

cash outside of the

Complex or unusually largetransactions.

Unusual patterns of transactions

We haveto ident

patterns

is set a


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conventional banking system

in order to reduce the

likelihood of detection.

which have no apparent economic or

visibly lawful purpose.

A sudden increase in business from

an existing customer that is not

consistent with known sources of

income.

Peaks of activity at particular

locations or at particular times.

Large numbers of transactions

slightly below the limit for verification

of ID.

send w

being

system

when a

be reac

allow fur

without i

appropri

MLRO o

Staff sh

suspicio

refer to

within th

Channel

Cash transactions Money transmission is

inherently high risk due to the

fact that it deals in the

movement of money, often

cash, across internationalborders.

High value cash remittances.

Cash funding and cash pay-outs.

All cash/

transact

the MLR

proof of

transactiwithout t

authoris

system w


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Cheque Encashment

Bureaux de Change

Most common risk to cheque

cashers is that of deception by

the customer. Third party

cheque cashers are not

normally exposed to large

scale money laundering

because the flow of cash goes

in the opposite direction to that

normally seen.

Bureaux de Change can be

attractive to money launderers

where large sums of money

can be exchange into small

denominations of a foreigncurrency

Multiple cheques in different names.

Sudden increase in cheque value.

Evidence of tampering on a cheque.

Several customers exchanging small

amounts to avoid identification

the evide

have info

Cheques

remittan

Compan

and all c

encashm

address

cheques

docume

proof of

in additio

MLRO a

For all cu

euro 5.0

identified

currency

10,000 oshowing

required

For all E


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Dollar transactions

Use of agents

Where we send or convert

monies in dollars our

regulatory risk increases as we

are obliged to consider US

regulations.

Agency relationship; where we

are dependent on an agent for

customer contact this can

create a risk of regulatory non-compliance and weaknesses

that could be exploited by

criminals or terrorists.

All dollar transactions

Little communication exists between

the money transmission business

and the agents.

custome

picture Id

is report

advised

suspicio

on Euros

200.00 n

All dollar

automat

OFAC d

We will a

undergo

scrutiny.

We will e

employe

launderin


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how to r

suspicio

to the No

We will m

with ID v

reporting

conducte

deputies

once a y

assessm

the direc

We will m

on daily

All agen

before s

will regis

of startin

Geography The countries in which weoperate and to which we send

monies to may give rise to a

higher risk of money

Source or destination of funds fromor to areas of high level of drugs

crime, terrorist activity etc.

We will anews on

terrorist

FATF, U


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laundering because of a

generally higher crime rate or

likelihood of money laundering

or terrorist financing.

Lack of knowledge regarding origin

or destination of funds.

HM Trea

the regu

advisor o

will be sc

Treasury

subscrib

We also

against t

above. I

refuse a

particula

requeste

Due Dilig


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The Law

Under the 2007 MLR, the company is obliged to provide all members of staff training

on the law relating to money laundering/counter terrorist financing. In line with that

obligation we set out below a summary of the legislation and the main issues that you

need to be aware of. The applicable legislation is set out in full. Please ensure that

you read the legislation so that you are aware of the potential criminal offences and

the penalties. Where appropriate, HMRC guidance on the legislation is included to

avoid confusion. Staff will be tested on their knowledge of the law as we are obliged

to ensure that you are aware of it.

Money laundering is generally defined as the process by which the proceeds of

crime, and the true ownership of those proceeds, are changed so that the proceeds

appear to come from a legitimate source.

Money laundering can arise from small profits and savings from relatively minor

crimes, such as regulatory breaches, minor tax evasion or benefit fraud. A deliberate

attempt to obscure the ownership of illegitimate funds is not necessary.

There are three acknowledged phases to money laundering: placement, layering and

integration.

Placement

Cash generated from crime is placed in the financial system. This is the point when

proceeds of crime are most apparent and at risk of detection.

Layering

Once proceeds of crime are in the financial system, layering obscures their origins by

passing the money through complex transactions. These often involve different

entities like companies and trusts and can take place in multiple jurisdictions.

Integration

Once the origin of the funds has been obscured, the criminal is able to make the

funds reappear as legitimate funds or assets.


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Proceeds of Crime Act 2002 (POCA)

POCA, as amended, establishes a number of money laundering offences including:

1. principal money laundering offences;

2. offences of failing to report suspected money laundering;

3. offences of tipping off about a money laundering disclosure;

4. tipping off about a money laundering investigation; and

5. prejudicing money laundering investigations.

POCA applies to all members of LCC TRANS SENDING LTD staff as our business is

in the regulated sector and so all the offences outlined above are applicable to you.

Sections 327 to 329: concealing, arranging, acquiring

These offences apply to all staff.

Section 327 it is an offence to conceal, disguise, convert, transfer or remove (from

the UK)criminal property

Section 328 it is an offence to become concerned in an arrangement which a

person knows or suspects facilitates the acquisition, retention, use or

control of criminal property

Section 329 it is an offence to acquire, use or have possession of criminal

property

These are the main money laundering offences and where we refer to Money

Laundering in this section, what is mean is the attempt, conspiracy to or commission

of these offences.

"Criminal property"is property which:

is or represents a person's benefit fromcriminal conduct;and

the alleged offender knows or suspects constitutes or represents such a

benefit .


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"Criminal conduct"is conducting which:

is an offence in any part of the UK; or

is an offence in the jurisdiction where the conduct took place

or where the conduct took place outside the jurisdiction, but would have if it

occurred in the UK, attracted a maximum penalty of over 12 months

imprisonment

These offences apply to the proceeds of all crimes and to any type of criminal

conduct, regardless of amount.

Penalty

These offences are punishable upon conviction by a maximum of 14 years

imprisonment.

The defences

You did not know or suspect that the money or property in question wascriminal property. Deliberately shutting your eyes to an obviously suspect

situation, will not constitute a defence

You made an authorised disclosurei.e.:

o a disclosure to a constable (the police), customs officer or a

nominated officer (i.e.using the firms internal reporting procedure) ;

and

o made in the form and manner prescribed in the regulations;

The companys nominated officer is our Money Laundering Reporting Officer,

Fatima Maria Oliveira Fernandesor, in her absence, her deputy, Seanna Manita.

Thus members of staff will have a defence by making a disclosure in accordance with

the companys internal reporting procedures which are set out below, the effect of

which is to report to our MLRO.


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Authorised disclosures can be made either before or after a "prohibited act"

occurs, i.e. before the completion of any transaction which amounts to a money

laundering offence. External disclosures, by the MLRO, are made to the Serious

Organised Crime Agency (SOCA).

Pre transaction disclosures. Where a suspicion has arisen before a "prohibited act"

occurs, it will be necessary to receive theappropriate consent before completing

any transaction which would amount to a prohibited act. If the prohibited act takes

place without this consent, than the disclosure defence will not apply.

Appropriate consent must be given by the person who received the authorised

disclosure, in this case the MLRO. However, the MLRO cannot give consent until a

report has been made to the SOCA and SOCA has given actual or presumed

consent (see below). It is an offence for the MLRO to give consent when they should

not have done.

Time limits for disclosure-- section 335 lays down time limits relating to the delay

between the authorised disclosure being made and the appropriate consent being

given or presumed.

If the person making the disclosure either receives appropriate consent or

hears nothing within seven working days, the transaction can proceed and the

disclosure defence will be available. The seven day period is known as the

"notice period";

If consent is refused within the notice period the transaction cannot safely

proceed unless consent has been given within the "moratorium period" or the

"moratorium period" has expired. The moratorium period starts when theappropriate consent is refused and lasts 31 days

Post transaction disclosureis a disclosure which is made after the "prohibited act

has occurred. In this case appropriate consent will not be required but the disclosure

defence will only apply if a person had a reasonable excuse not to report beforehand.

Adequate consideration defence-- there is a defence to section 329, that a person

has been paid a proper amount for providing goods and services. However this

defence does not apply if the person knew or suspected that the goods or services


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they were providing, and being paid for, might help another to carry out criminal

conduct.

Sections 330 failure to disclose: regulated sector

The s330 offence in the Act has been amended by SOCA in a number of key

respects:

The offence applies when a person:

knows or suspects, or

hasreasonable groundsfor knowing or suspecting that another person is

engaged in money laundering.

can identify the money launderer or the whereabouts of the laundered

property

or that he believes that the information he has may assist in identifying the

other person or the whereabouts of any of the laundered property

The disclosure must be made as soon as is practicable and must have been made in

the course of business. The disclosure must be made to the MLRO or to SOCA.

This offence introduces an objective test for knowledge or suspicion. This means

that a person may be guilty of this offence if there were reasonable grounds for

knowledge or suspicion i.e. they should have known or suspected.

Penalty- punishable on conviction by a maximum of five years imprisonment.

Defences to failure to disclose: regulated sector

Employees in the regulated sector who have not received training about money

laundering from their employer may have a defence. However this defence is only

available if the employee did not have actual knowledge or suspicion. In these

circumstances there would be ramifications for the employer.

It could also be a defence if the person has a "reasonable excuse" for not disclosing

the information.


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Section 333A (1) and (3) tipping off

S333A(1) disclosing a suspicious activity report (SAR).It is an offence for a person

to make a disclosure which is likely to prejudice an investigation, when the person

knows or suspects that an authorised disclosure has beenmade.

S333A(3) disclosing an investigation. It is an offence to disclose that an

investigation into a money laundering offence is being contemplated or carried out if

that disclosure is likely to prejudice that investigation.The key point is that you can

commit this offence, even where you are unaware that a SAR was submitted.

The disclosure in this context means any form of communication to anyone, not just

our own customer.

It is a defence if the person did not know or suspect that the disclosure was likely to

prejudice an investigation.

S333B Disclosures within an undertaking or group etc

It is notan offence if an employee of a firm discloses that a SAR has been made if it

is to an employee of the same business.

Any concerns with regard to tipping off should be referred to the MLRO.

Terrorism Act 2000 (TA)

The TA, as amended, establishes several offences about engaging in or facilitating

terrorism, as well as raising or possessing funds for terrorist purposes. It establishes

a list of organisations the Government believes are involved in terrorism.

The Terrorism Act applies to all persons. There is a failure to disclose offence and

tipping off offences for those operating within the regulated sector.


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Section 18 money laundering

It is an offence to enter into or become concerned in an arrangement facilitating the

retention or control of terrorist property by, or on behalf of, another person including,

but not limited to the following ways:

By concealment

By removal from the jurisdiction

By transfer to nominees

It is a defence if you did not know, and had no reasonable cause to suspect, that the

arrangement related to terrorist property.

Section 21A- tipping off

It is a criminal offence for those in the regulated sector who fail to make a disclosure

to either a constable or the firm's nominated officer where there are reasonable

grounds for suspecting that another person has committed an offence.

Section 21D (1) and (3) tipping off offences

Section 21D (1) disclosing a suspicious activity report (SAR).It is an offence to

disclose to a third person that a SAR has been made by any person to the police, HM

Revenue and Customs, SOCA or a nominated officer, if that disclosure might

prejudice any investigation that might be carried out as a result of the SAR.

Section 21D (3) disclosing an investigation.It is an offence to disclose that an

investigation into allegations relating to terrorist property offences is being

contemplated or carried out if that disclosure is likely to prejudice that investigation.

Section 21E Disclosures within an undertaking or group etc

It is not an offence if an employee of a firm discloses that a SAR has been made if it

is to an employee of the same business.

Any concerns with regard to tipping off should be referred to the MLRO


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European Union Wire Transfer Regulations 1781/2006

This regulation applies to our business as we transfer money on behalf of clients. Its

basic aim is to ensure that complete information on the person sending money

(payer) is sent with the transfer to the beneficiary (payee). It is to enable law

enforcement to detect and trace the assets of criminals or terrorists. We must also

identify and verify customers who transfer in excess of 900, 00. For payments

within the EU we need only send a name and account number.

Payment Service Regulations 2009

The regime originates from a European Community law The Payment Services

Directive (PSD). The aim of the PSD is to foster a single market in retail payment

services across the European Economic Area by removing barriers to entry and

ensuring fair market access to enhance competition in payment services; and

establishing the same set of rules across the EEA on information requirements and

other rights and obligations that will be applicable to many payment services

transactions in the EEA.

UK BRIBERY 2010

The Bribery Act 2010 came into force on 1 July 2011. it amends and reforms the UK

criminal law and provide a modern legal framework to combat bribery in the UK and

internationally.

The Bribery Act creates the following offences:

1) Active bribery: promising or giving a financial or other advantage

2) Passive bribery: agreeing to receive or accepting a financial or other

advantage3) Bribery of foreign public officials

4) The failure of commercial organisations to prevent bribery by an associated

person

Under the current law imprisonment for up to seven years with unlimited fine will

increase under the Bribery Act to a maximum of 10 years imprisonment.


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SW complying with the new regulation produced a Small World Group Anti-BriberyPolicy: covering the giving and acceptance of bribes and distributed to all directors,employees and agents.

HM Treasury AFU

HM Treasury maintains a list of sanctioned individuals and countries with whom any

financial dealing is restricted. It is a criminal offence to make payments or allow

payments to be made to these targets. Sanctions are incorporated into UK law by EC

Regulations or by statutory instruments.

In general terms, any person to whom the relevant Statutory Instrument applies who,

except under the authority of a licence granted by HM Treasury under the relevant

Statutory Instrument, makes any funds, economic resources or, in some

circumstances, financial (or related) services available directly or indirectly to or for

the benefit of persons listed under the relevant Statutory Instrument or EC Regulation

is guilty of an offence.

The MLRO undertakes regular client screening against the relevant

databases including whenever an update is issued by the AFU. As noted

above any client is automatically screened using the Bridger Insight

platform. Lists included in the Bridger Insight screening are:

Bank of England Consolidated ListUK HM Treasury ListUK FSABureau of Industry and Security ListConsolidated List - AustraliaConsolidated List - Canada

DTC Debarred PartiesEuropean Union Consolidated ListFBI Hijack SuspectsFBI Most WantedFBI Most Wanted TerroristsFBI Seeking InformationFBI Top Ten Most WantedHong Kong Monetary Authority ListInterpol Most WantedMonetary Authority of Singapore ListNonproliferation Sanctions, U.S. Department of State, ISNOFAC Non-SDN Entity ListOFAC SanctionsOFAC's Specially Designated Nationals & Blocked Persons


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Politically Exposed PersonsPrimary Money Laundering ConcernPrimary money laundering concern - JurisdictionsTerrorist Exclusion ListUnauthorized BanksUnited Nations Consolidated ListWorld Bank Debarred PartiesWorld Bank Ineligible FirmsTerrorist Exclusion ListReserve Bank of AustraliaPrimary Money Laundering JurisdictionsPeoples Bank of China (PBC)OSFI CountryOSFI Consolidate ListOIG ExclusionsOffshore Financial CentersJapan MOF Sanctions

Japan Meti-WMD ProliferatorsJapan FSAIreland Financial Regulator unauthorized firmsHVD LDPHong Kong Monetary AuthorityHM Treasury Investment Ban listForeign Agents RegistrationsFATF Financial Action Task ForceCommodity Future Trading Comission SanctionChefs of State and Foreign Cabinets MembersAustralia Dept of Foreign affairs and tradeEPLS

In accordance with the MLR 2007, LCC Trans-Sending Ltd is subscribed to

HM Treasurys email alert system at www.hm

treasury.gov.uk/fin_crime_mailinglist.htm.All new alerts and updated received

from HM Treasury are reported in our AML Monthly Report.

All customers and beneficiaries names are checked against international

lists of sanctioned targets. The system is able to make this check against

more than 25 international sanction lists using the Bridger Insight platform.

If a similar matching result is found, we do the following:

- Apply EDD and add customer to our internal watch list in order to

carry out ongoing monitoring.

If an exact matching result is found, we do the following:

- Make a disclosure to the relevant authority (Asset Freezing Unit or

SOCA) and block the customer in our operational system until consent

is given to proceed or refuse. In addition, we may cease the business


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relationship with the customer allowing 30 days notice to comply with

out Terms & Conditions.

The Money Laundering Regulations 2007

The Money Laundering Regulations 2007 repeal and replace the Money Laundering

Regulations 2003. They set requirements for the anti-money laundering regime within

our business and outline the scope of customer due diligence.

The regulations aim to limit the use of MSB for money laundering by requiring

businesses to know their clients and monitor the use of their services by clients.

Regulation 3 (1) of the 2007 MLR provides:

3 (1) Every person who carries on relevant business in the United Kingdom must --

(a) Comply with the requirements of regulations 4 (identification

procedures), 6 (record-keeping procedures) and 7 (internal reporting

procedures);

(b) Establish such other procedures of internal control and

communications as may be appropriate for the purposes of forestalling

and preventing money laundering; and

(c) Take appropriate measures so that employees are --

(i) Made aware of the provisions of these Regulations and of section

340 (11) of POCA; and

(ii) Given training in how to recognise and deal with transactions which

may be related to money laundering.

In respect of 3(1)(b) above, the overall responsibility for implementing internal control

procedures, including compiling this section of the office manual is with the

Compliance Director Nicholas Day, who is assisted by the Training Manager and

MLRO Fatima Maria Oliveira Fernandes.


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For the purposes of Regulation EC 1781/2006 on information on the payer

accompanying transfers of funds (commonly known as the Payments Regulation or

the Wire Transfer Regulations), for amounts of between 1,000 euro (approximately

900), and 15,000 euro (approximately 12.500), evidence of address need not

necessarily be obtained. However it is this companys policy to obtain and verify

evidence of the customers address. We allocate each customer with an account

number. This number will be sent with the customers name to comply with the

regulation.

In terms of beneficial ownership, we will ask every customer whether they are acting

in their own capacity or on behalf of another person. If they are acting for another

person then we will require details of such.

INDIVIDUALS

Met face to face? Yes and normal risk obtain:

Either proof of identity photo identity

Or: proof of identity non photo identity and proof of address

(please note P.O. boxes are not acceptable addresses)

or date of birth (can be electronic).

No and/or higher risk (EDD) obtain:

either proof of identity photo identity and an additional piece

of evidence

Or: proof of identity non photo identity, proof of address

(please note P.O. boxes are not acceptable addresses)or date of birth


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Plus: an additional piece of evidence.

Sources of evidence

List 1: Evidence of identity

Acceptable photo identity

Valid passport; or

Valid photo card driving

licence (full or provisional);

or

National identity card (non

UK nationals issued by EEA

member states and

Switzerland); or

Firearms certificate or

shotgun licence; or

Identity card issued by the

Electoral Office for Northern

Ireland

Acceptable non-photo evidence of

identity:

Documents issued by a

government department,

incorporating the persons name

and residential address or their

date of birth. E.g.

A current UK full driving

licence old version (not

List 2: Evidence of address or date of birth

Instrument of a court appointment

(such as a grant of probate,

bankruptcy); or

Current council tax demand letter or

statement; or

Current (within the last 3 months) bank

statements, or credit/debit card

statements issued by a regulated

financial sector firm in the UK, EU or

JMSLG equivalent jurisdiction; or

A file note of a visit by a member of

the firm to the address concerning(home visit); or

An electoral register search showing

residence in the current or most recent

electoral year (can be done via

http://newcorp.192.com/search/index.c

fm); or

A recent (last available) utility bill (gas,

water, electricity, telephone not

mobile phone bills); it must be a bill or

statement of account (not

correspondence); or

Valid photo card driving licence (full or

provisional); or


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provisional licences); or

Evidence of entitlement to a

state or local authority

funded benefit (including

housing benefit and council

tax benefit), tax credit,

pension, educational or

other grant; or

Documents issued by

HMRC, such as PAYE

coding notices and

statements of account (NB:

employer issued documents

such as P60s are not

acceptable)

End of year tax deduction

certificates.

A current UK full driving licence old

version (not provisional licences); or

Evidence of entitlement to a state or a

local authority funded benefit

(including housing benefit and council

tax benefit), tax credit, pension,

educational or other grant; or

Documents issued by HMRC, such as

PAYE coding notices and statements

of account (NB: employer issued

documents such as P60s are not

acceptable);or

A firearms/shotgun certificate; or

A solicitors letter confirming recent

house purchase or land previousaddress).

When accepting evidence of identity from a customer, it is important that we make

sufficient checks on the evidence provided to satisfy us of the customers identity,

and that we keep a record of the checks made.

Checks on photo ID may include:

Visual likeness against the customer

Does the date of birth on the evidence match the apparent age of the

customer?

Is the ID valid?


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Is the spelling of names the same as other documents provided by the

customer?

Checks on secondary evidence of ID may include:

Do the addresses match the address given on the photo ID?

Does the name of the customer match with the name on the photo ID?

Electronic verification

As a secondary proof of Identification, We also screen customers on electronic

verification for those that we can not have enough proof of identification in hard paper

Electronic verification must be done using our software provider Safe Credit.

Electronic verification should meet a standard level of confirmation before it can be

relied upon. In circumstances that do not give rise to suspicion or significant risk ofimpersonation fraud, the standard level of confirmation is:

One match on an individuals full name and current address, and

A second match on the full name and either his current address or his date of

birth.

Where the customer is not physically present for identification purposes we must

obtain further evidence of identity in line with our stated policy. This means that we

will either ask for further forms of identity or perform further checks to verify the

information supplied.


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The system is also able to detect linked (aggregate) transactions which are identified

by:

- Similar/same names/surnames

- Matching ID number

- Similar/same telephone number / address

-

Customers who cannot provide the standard evidence

Some of our customers may not be able to produce identification information to meet

the standard requirement, e.g. migrant workers, refugees and asylum seekers,

dependent spouses/partners or minors. In these cases we will need an approach that

compensates for the difficulties that such customers may face in providing the

standard evidence of identity.

We must record why the standard requirements cannot reasonably be applied.

The following table provides examples of documents that provide evidence of identity

for some types of financially excluded customers. The list is not exhaustive. Any

problems should be referred to the MLRO.

Customer Documents(s)

Economic National Passport, or

Migrants National Identity Card (nationals of EEA)

Refugees(Those that are Immigration Status Document with Residence Permit, or

not on benefit)

IND travel document (i.e. Blue Convention Travel doc, or Red

Stateless Persons doc, or Brown Certificate of identity

doc)


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Where we decide that a customer cannot reasonably meet the standard identification

requirement, and the provisions in the table above cannot be met, we may accept as

identification evidence a letter or statement from an appropriate person who knows

the individual, that indicates that the person is who he says he is.

Some categories of financially excluded customers may represent a higher risk of

money laundering. We will consider enhanced monitoring of transactions conducted

by anyone assessed as such.

Non face to face customers

Non face-to-face customers present an inherent risk of impersonation fraud which we

must take account of in framing our internal policies and procedures. The MLR 2007

requires that we apply enhanced due diligence measures, on a risk-sensitive basis,

when we dont physically meet our customers.

Therefore, we must apply additional verification checks to mitigate the risk of

impersonation fraud. These checks may include:

Requiring additional documents, data or information to verify the customers

identity

Applying supplementary measures to verify the documents supplied

Requiring the first transaction to be carried out through an account in the

customers name with a UK or EU regulated bank or one from a comparable

jurisdiction.

Telephone contact with the customer at a home or business number which

has already been verified, using it to verify additional aspects of personal

identity information provided during the application process.

Communicating with the customer at an address which has already been

verified, for example by letter.


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Photocopied identity documents can be accepted as evidence of ID provided that

each copy document has an original certification by an appropriate person to confirm

that the person is who they claim to be.

An appropriate person is an independent professional person who is not already a

friend or relative of the applicant. For example:

Family GP

Accountants

Civil Servant

Teacher

Solicitor

Notary

Post Office Branch employee

Employer

In addition to providing a written certification on the copy document to confirm the

identification of the applicant, the certifying individual should also provide their

business contact details.

Customers other than private individuals (such as companies)

General Obligations

Certain information about the entity should be obtained as a standard requirement.

We will then assess the risk of money laundering or terrorist financing, based on the


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combination of factors outlined in our risk matrix. We will then decide the extent to

which the identity of the entity should be verified, using reliable, independent source

documents, data or information. We will require information in respect of some of the

individuals behind or connected to the customer for the purpose of being satisfied

that we know who the beneficial owners of the entity are.

As part of the standard evidence, we must know the names of all individual beneficial

owners who own or control more than 25% of the customer, even where these

interests are held indirectly.

Information must be obtained on the nature and purpose of the business relationship

and anticipated size and volume of transactions. We do this by asking our clients to

complete our Basic Information Report. See attached B

Corporate customers

We will obtain the following as standard in relation to corporate customers:

Full Name

Registered Number

We will also verify the identity of the corporate entity from:

Either a search of the relevant company registry

Or confirmation of the companys listing on a regulated market (see the FSA

handbook glossary for a definition of regulated market)

Or a copy of the companys certificate of incorporation

This standard evidence is likely to be sufficient to verify the identity of most corporate

customers. If, however, any of the circumstances outlined in our risk matrix exist then


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require additional information to be provided in order to be satisfied as to the

customers identity, including, where appropriate, the nature and purpose of the

customers business activities and the source of funds.

In general the structure, ownership, purposes and activities of many private

companies will be clear and understandable.

The standard evidence above on corporate customers should be obtained and

verified, plus, additionally, the following information should be obtained and verified:

Names of all directors (or equivalent)

Names of beneficial owners/shareholders holding over

25%

Names of all directors (or equivalent)

Other entities

Further guidance on verifying the identity of a range of non-personal entitles is

provided in the JMLSG Anti-Money Laundering guidance for FSA regulated firms.

If any of these types of organisation wish to use our service please refer the matter to

the MLRO.

PROCEDURE FOR REPORTING SUSPICIOUS CIRCUMSTANCES

Any member of staff, who is suspicious that a transaction may involve money

laundering or who becomes aware in the course of their work that someone else is

involved in money laundering, must make a disclosure to the MLRO using the report

form found in attachment. Copies of the report form are also to be found in the

central Database


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Once completed, the form should be printed off. The member of staff making the

report must sign and date the form or click on suspicious box in the system to create

a digital ISAR which will be sent automatically to the MLRO.

The form must then be hand delivered by the reporting member of staff to the MLRO.

The MLRO will sign a receipt to show date and time of report.

Upon receipt of the form by the MLRO, they will then decide what is to be done as a

result of the report, e.g., whether the matter must be reported to the SOCA or not, or

further enquiries made and record its decision and the reason for it on the report form

on the Database. The member of staff concerned must be informed of the decision

and the reasons for it.

If the matter is referred to the SOCA the MLRO will be responsible for completing the

SOCA report form and discussing with the reporting member of staff how matters

with the client/transaction are to be conducted from that stage, bearing in mind that

POCA prohibits us from continuing with the prohibited act which is being reported to

SOCA. The SOCA report form must be signed off by the MLRO or her deputy or, in

both of their absence, a director.

In accordance with the tipping off provisions of POCA, the report must not be

discussed with the customer.

We must not proceed with a transaction whilst we await consent from SOCA. SOCA

is given 7 working days (sat/sun or bank holidays not included) to consider the report.

If we hear nothing then we may continue with the transaction but not inform the clientabout the report. SOCA may give consent to proceed earlier than this time limit. They

may also refuse consent in which case they have a further 31 calendar days

(including sat/sun or bank holidays) to further consider the report. After this they must

either begin proceedings or allow the transaction to continue. Attached M shows our

SOCA reporting timetable.

The MLRO will report using one of the existing standard methods and in the majority

of cases will utilise SAR Online. (www.soca.gov.uk).


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If the MLRO decides to use any other method fax, disc, CD ROM or post she will

use the standard SARs form, which must be typed.

Any paper file for each matter will be kept by the Compliance director, who should be

notified of each matter.

There must be no record on the Customer file or on the computer system which

refers in any way to suspicious circumstances reporting, money laundering, etc., to

avoid the risk of tipping off. It is a criminal offence to inform a customer that a SAR

has been submitted, or to inform them of an investigation into their affairs.

All records of SAR will be kept in the central reporting file, which is kept in the

MLROs office.

Suspicion Indicators

The following lists are provided for staff as an aid to whether a particular transaction

may be suspicious. The list is not exhaustive and staff should consider all the

circumstances of a particular transaction before deciding whether to report any

issues to the MLRO.

New customers and occasional or one-off transactions:

Checking identity is proving difficult.

The customer is reluctant to provide details of their identity.

There is no genuine reason for the customer using the services of an MSB

A cash transaction is unusually large.

The cash is in used notes and/or small denominations.

The customer requests currency in large denomination notes.

The customer will not disclose the source of cash.

The explanation for the business and/or the amounts involved is not credible.

A series of transactions are structured just below the regulatory threshold for

due diligence identity checks.

The customer has made an unusual request for collection or delivery.

Transactions having no apparent purpose or which make no obvious

financial sense, or which seem to involve unnecessary complexity.

Unnecessary routing of funds through third parties.


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Regular and established customers.

The transaction is different from the normal business of the customer.

The size of frequency of the transaction is not consistent with the normal

activities of the customer.

The pattern of transactions has changed since the business relationship was

established.

Money transfers to high-risk jurisdictions without reasonable explanation,

which are not consistent with the customers usual foreign business dealings.

Sudden increases in the frequency/value of transactions of a particular

customer without reasonable explanation.

Examples where customer identification issues have potential to indicate suspicious

activity.

The customer refuses or appears reluctant to provide information requested.

There appears to be inconsistencies in the information provided by the

customer.

The customers area of residence is inconsistent with other profile details

such as employment.

An address appears vague or unusual.

The supporting documentation does not add validity to the other information

provided by the customer.

The customer is in a hurry to rush a transaction through, with promises to

provide the information later.

Examples of activity that might suggest to staff that there could be potential terrorist

activity.

The customer is unable to satisfactorily explain the source of income.

Frequent address changes.

Media reports on suspected or arrested terrorists or groups.


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RECORD KEEPING

CDD and transaction records

We will store records of all transactions for 5 years from the conclusion of thetransaction on behalf of our customers or the end of the relationship.

The records we must keep are:

1. copies of or references to the evidence of the customers ID obtained

under our CDD requirements; and

2. the supporting evidence and records in respect of the business

relationships and occasional transactions, which are subject of CDD orongoing monitoring.

SAR PROCEDURE

STAFF MLRO

SAR FILE

SOCA

Report any suspicionsSTOP TRANSACTION

Use internal report formNo information as to suspicionsto customer

If AppropriateSubmit SAR

Uses prescribedmethod

If Necessary further information about circumstances obtained

Keep records for 5years

7 workingdaysNo consent

LCCTransaction Continue as normal. No information to client about report

LCC

7 working days-consent given

31 calendar daysNo information on reportTo be given to customer

No report deemednecessary

Consent

No ConsentTransactionRefused

Customer


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All records of CDD documentation are scanned and upload into our operational

system linked in the customer unique reference number.

INTERNAL AND EXTERNAL SAR RECORDS

As previously indicated, all internal reports will be kept on the SAR file as opposed to

the customer file. The report will be kept for 5 years.

In addition to this all SAR submitted including correspondence with SOCA or HMRC

will be kept for unlimited period of time.

TRAINING RECORDS

The company maintains records of all AML training undertaken by staff, the date it

was provided and the results of any tests if applicable. These records will be kept for

5 years following the end of employment with the company.

AGENTS RECORDS


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ANNEX I

Terms & Conditions

Ant-Money Laundering and Bribery Prevention

Policies and Procedures


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As used in our Terms and Conditions, the terms:

"Prohibited purpose"means any unlawful purpose; the purpose of making or receiving payment for gambling services, gamblingchips or gambling credits; the purpose of making or receiving payment for banking or other financial services; or the purpose ofsending a payment to yourself as the recipient;

"Recipient"means the person identified as the beneficiary of a money transfer (whether that money transfer is initiated by a senderusing the Service or by a person using another money transmission service);

"Sender"means the person who initiates the carrying out of a money transfer by using Service;

Authorised person is the person who is formally and properly empowered to perform on behalf of the sender.

"Transaction"means each money transfer that you initiate under, and each other use that you make of, the Service;

"We", "our"or "us"means LCC Trans-Sending, Ltd., which is a company incorporated under the laws of England and Wales and

whose registered office is at Units 3-4 Sycamore Court, 168-170 Bermondsey Street, SE1 3TQ London.

"Service"means any or all of the services for money transfer which are made available by us;

"Site"means the website operated by us to provide online money transmission services and related information facilities;

UTN means the unique transaction number which will be issued to you and which the recipient will required to provide in order toauthorise us or our agents to make payment to the recipient; and

"You"or "your"means any person who uses the Site or the Service, whether as a sender or as a recipient.

Business Day means official working hours excluding weekends and public holidays.

Value Date : means the date on which a transaction actually takes place.

Payment order means the instruction to transfer funds sent via paper and/or electronic means.

All references in Our Terms (unless otherwise stated) (a) to a person or personsshall include any natural person, company, firm, partnership, trust, public body orother organisation; (b) to clauses are to clauses of Our Terms; (c) to anylegislation (including statutes, statutory instruments, statutory provisions orregulations) shall include them as amended or re-enacted from time to time; and(d) made in the singular shall include the plural and vice versa.

1 MONEY TRANSFERS - OUR OBLIGATIONS

1.1 Before agreeing to undertake a transaction we will provide you with a draft contract or payment order which,together with these Terms, will set out the information which we are obliged to provide to you

(a) The maximum total fee that the Sender will be charged by us, together with a breakdown where applicable. Ifwe believe that person to whom you send the money may also have to pay a fee, then we will tell you.

(b) An indication of the exchange rate that we will apply to your transaction, or the reference exchange rate uponwhich the actual exchange rate will be based. If a further exchange rate may be applied we will tell you toexpect this.

(c) Information on where the person should collect the money from and what they have to do, if it is to be madeavailable in cash

(d) An indication of the maximum time that it will take for the transaction to be completed i.e. the time until fundswill be available to the person to whom you are sending the money.

(e) Information on cancellation procedures and any charges for cancelling or amending a transaction(f) In relation to any Money Transfer that we have agreed to perform for you,

(a) if we are in receipt of your onward payment instructions by the Value Date and time we specify, as soonas practicable after the Value Date (or, if the Value Date is not a Business Day, as soon as practicableafter the first Business Day following the Value Date); or (b) if we are not in receipt of your onwardpayment instructions by the Value Date and time we specify, as soon as practicable after we havereceived your onward payment instructions, but you should be aware that it can take more than 5 (five)Business Days for the funds to clear, depending on local banking arrangements.

1.2 Upon completion of a transaction we will provide you with the following in writing:(a) A transaction reference number that is unique to your payment(b) Confirmation of the exact amount we are sending for you(c) The charges or fees that you have paid to us for this service, together with breakdown where applicable.(d) The amount of the Transaction in the currency used in the payment order.(e) The amount of the Transaction in the currency in which the Recipient will receive the money.

(f) The date on which we received the payment order from the Sender.(g) The exchange rate that has been applied to your transaction(h) Information on where the person to whom you are sending the money can collect it or confirmation of the bank

to which the money has been sent

TERMS AND CONDITIONS


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(i) When the money will be available for the person to whom you are sending it and whether this timescale isdefinite or the best estimate that we can make

(j) In the case of cash collections, what the beneficiary has to do in order to collect the money.(k) The procedure to follow if you have a need to query this transaction. We will advise you how long it will take us

to provide an answer or an update.

1.3 Our agreement with you is that we will take reasonable care to provide the Service. As such, we agree to provideyou with the money transfer services and the related information facilities made available from time to time by us.

1.4 We do not accept any responsibility to you for:(a) the goods or services which you pay for by using the Service;(b) malfunctions in communications facilities which cannot reasonably be considered to be under our control and

that may affect the accuracy or timeliness of messages you send to us;(c) any losses or delays in transmission of messages arising out of the use of any Internet access service provider

or caused by any browser or other software which is not under our control;(d) viruses caused by third parties;

1.5 We have no obligation to you to initiate or perform a money transfer or other transaction as part of theService if:

(a) we are unable to obtain satisfactory evidence of your identity;(b) we have reason to believe that the transaction message is incorrect, unauthorised or forged;(c) you provide us with incorrect or incomplete information or if your send order is not given to us sufficiently in

advance to allow for timely provision of the requested transaction,and we do not accept any liability for damages resulting from non-payment or delay in payment of a moneytransfer to a recipient or failure to perform a transaction under the Service by reason of any of these matters .

1.6 The information the Sender needs to provide in order for the transaction to be executed:

(a) Senders full name, address, date of birth, phone number, nationality, occupation, Identification (passport, drivelicence or EEA ID) for all transactions, and proof of source of money for transactions equal or greater thanEuros 5000 per month.

(b) Beneficiarys full name, phone number, account number, bank name.(c) We may request further information if necessary.

1.7 We may refuse to provide the Service (in whole or in part) to you if we understand that you dont have enoughinformation to follow the regulatory or governmental authority.

1.8 We may suspend the operation of the Service in whole or in part if, in our absolute discretion, we consider itappropriate to do so by reason of any circumstances beyond our control. We undertake that if the Service isinterrupted (whether by us, any third party service provider or otherwise) for any reason we will take reasonable careto minimise the duration of any interruption. Provided we comply with this undertaking, we shall not be liable to youfor any loss or liability which may be suffered or incurred by you as a result of any such interruption, even if causedby our negligence, except where any such interruption is caused by our fraud.

2 MONEY TRANSFERS - YOUR OBLIGATIONS

2.1 You agree to pay our charges for each money transfer or other transaction which you initiate or request under the

Service. Before we can perform any of Our Services for you, you must register with us. Inorder to complete your registration, you must provide us with all the details we require from you, including details relatingto your identity and proof of address and any other information we may require from you to enable us to complete our anti-money laundering procedures.

2.2 You will promptly supply us with all information and documentation which we may ask you for at any time to enableus to comply with any legal requirements on us relating to our Services, including as required by Third EuropeanDirective 2007.

2.3 You may authorise another living individual to provide us with instructions on your behalf. In these circumstances,we will treat the instructions of the Authorised Person as if they came from you.

2.4 You are responsible for the completeness and accuracy of all information you provide to us at any time, includingany in your request and your nominated account details. You must always provide us with instructions, and makesure any authorised person provides us with instructions, in the English language.

2.5 You acknowledge and agree that:

(a) when you register with us or submit a send order, you will provide us with true, accurate, current and completeinformation and sign the receipt to confirm it;(b) you will maintain and promptly update such information to keep it true, accurate, current and complete;(c) you will not use the Service for or in connection with any prohibited purpose;(d) you will not initiate a money transfer or other transaction under the Service in breach of these Terms and

Conditions or any other restriction or requirement of use described on the Site; and(e) You are responsible for the security of the UTN.

2.6 You acknowledge and agree that information about you, and the services we provide to you are confidential,however may be provided by us from time to time to regulatory or governmental authorities, bodies or agencieswhere we are required by law to do so.

2.4 All information must be kept in our data base for up 5 years.

2.7 All currency converted under the Service is converted at our rate of exchange.

2.8 You will be liable to us for all losses which we suffer or incur relating to any fraudor fraudulent activity by you at anytime.

3 CANCELLATION AND REFUNDS


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3.1 You have the right to cancel orders up to the time at which payment has been made to the recipient. You mayexercise this right by:

(a) telephoning us on (+44) 020 7378 1100;(b) writing to us at Units 3 -4 Sycamore Court, 168-170 Bermondsey St, SE1 3TQ;(c) sending us a fax to (+44) 020 7378 1220; or(d) e-mailing us at [email protected] will accept any notice which indicates, in whatever form of words that you wish to cancel your agreement with us.

3.2 If you exercise your right to cancel under clause 3.1 after you have sent a money transfer order to us, we will

reimburse any payments which you made to us before cancellation, but:(a) We will not reimburse you if we have paid the money transfer to the recipient before we receive your notice of

cancellation.(b) We may make a cancellation charge if the reason for the return of the money is not caused by our part, only

the net value of the transfer will be reimbursed. We will keep the commission previously charged. Reimbursedcannot exceed 10% of the total value of the paymen