Anti-Money Laundering Policy

CENTRIX ACCOUNTANTS has a zero-tolerance approach to money laundering, terrorist financing, proliferation financing and the facilitation of tax evasion. We will not form or continue a business relationship where we cannot complete satisfactory Customer Due Diligence, where the purpose of the relationship is unclear, or where we know or suspect that criminal property is involved.

This policy applies to all partners, staff, contractors and systems used in the practice. It is a condition of every client engagement. Failure to follow it is a disciplinary matter and may be a criminal offence.

We design our systems around the following UK regime (as amended from time to time) and the guidance issued by our professional body and AML supervisor:

Where sector-specific rules apply (for example, solicitors’ client-account reporting or charity registrations), those rules sit alongside this policy and do not reduce it.

The practice maintains a Nominated Officer / Money Laundering Reporting Officer (MLRO) with independence, seniority and direct access to the principals. The MLRO is responsible for receiving internal reports, deciding whether a Suspicious Activity Report (SAR) should be submitted to the National Crime Agency, managing consent requests, and overseeing AML training and file quality.

The principals approve a firm-wide risk assessment at least annually and whenever our services, client profile or the national risk assessment changes materially. AML is a standing item of practice governance. Day-to-day CDD is performed by the senior specialist owning the engagement; it is not delegated to untrained staff.

Before onboarding, and periodically thereafter, we assess money-laundering, terrorist-financing and proliferation-financing risk at firm level and at client / matter level. Our assessment considers the UK National Risk Assessment, professional-body guidance, and the following factors as they apply to a luxury corporate tax and advisory practice:

The output of the assessment determines whether Simplified, Standard or Enhanced Due Diligence applies, the depth of source-of-funds enquiry, and the frequency of ongoing monitoring. High-risk relationships require documented principal approval.

We apply Customer Due Diligence (CDD) when we establish a business relationship, when we carry out an occasional transaction within the MLR thresholds, when we suspect money laundering or terrorist financing, or when we doubt the adequacy of previously obtained documents. We do not complete professional work that is dependent on the relationship until CDD is complete, except where the Regulations specifically permit limited continuation while CDD is finalised — and never where there is suspicion.

Standard CDD includes identifying the client; verifying identity on the basis of reliable, independent sources; identifying beneficial owners and persons with significant control; understanding ownership and control structure; and obtaining information on the purpose and intended nature of the relationship.

We may use electronic identity-verification and Companies House ID-verification tools. Electronic checks supplement, and do not automatically replace, documentary or professional-judgement verification where risk is elevated.

Enhanced Due Diligence (EDD) is applied automatically, and additional measures are documented, where the Regulations or our risk assessment require it. EDD typically includes senior-management approval, additional identity and control information, more detailed source-of-funds and source-of-wealth evidence, and enhanced ongoing monitoring.

Simplified Due Diligence is used only where the MLR permit it and our firm-wide assessment supports low risk (for example, certain listed companies or public authorities). Simplified measures never apply where there is a suspicion of money laundering or terrorist financing.

All new clients, relevant beneficial owners and instructing officers are screened against UK sanctions lists and PEP databases at onboarding and at risk-based intervals thereafter. A sanctions match results in an immediate freeze on activity pending MLRO and, where required, OFSI assessment. We do not provide services that would breach UK financial sanctions.

PEP relationships are not prohibited but are always treated as high risk, require EDD and principal approval, and are subject to closer monitoring of source of wealth and the rationale for the engagement.

We obtain a clear explanation of how fees will be paid and, where the risk profile requires it, evidence of the source of funds and source of wealth supporting the client’s business or the particular transaction. Banking of substantial or unexpected sums, third-party payments, or funds from high-risk jurisdictions will trigger additional enquiry and, where appropriate, delay or refusal of the work.

Cash is not accepted except in trivial amounts, if at all. Third-party payment of fees is permitted only after the payer is identified and the rationale is documented and accepted by the MLRO or engagement principal.

CDD is not a one-off onboarding exercise. We scrutinise transactions and instructions throughout the relationship to ensure they are consistent with our knowledge of the client, its business and risk profile. Trigger events for a CDD refresh include a change of control, new high-risk jurisdiction, unusual tax or cash-flow pattern, adverse media, or a material change in the services we provide.

The client workspace and our working papers support an audit trail of instructions, documents received and screening. Monitoring frequency is higher for EDD relationships.

Any partner or member of staff who knows, suspects, or has reasonable grounds to know or suspect that a person is engaged in money laundering or terrorist financing must report internally to the MLRO without delay. The MLRO will consider the report, the engagement file and the legal tests under POCA and the Terrorism Act, and will submit a SAR to the National Crime Agency where required.

Where a prohibited act would otherwise be committed, we will not proceed without an authorised disclosure and, where the law requires it, appropriate consent / a defence against money-laundering (DAML) from the NCA. We will not complete a transaction or disclose the existence of a SAR in a way that constitutes tipping off or prejudicing an investigation.

Staff must not discuss internal reports or SARs with the client, introducers, or anyone outside the MLRO process, other than as permitted by law (for example, specified disclosures to a professional legal adviser for the purpose of obtaining legal advice).

We retain CDD documents, risk assessments, screening results, internal reports and supporting working papers for at least five years after the end of the business relationship or occasional transaction, in accordance with the MLR. Records are stored securely, with access limited on a need-to-know basis, and are not used for unrelated commercial purposes after the retention clock starts to run on relationship end.

Destruction of AML records before the statutory period, or fabrication of CDD, is prohibited. Our Privacy Policy explains how AML data sits alongside UK GDPR duties; legal-obligation processing under the MLR will often limit erasure requests during the retention period.

All relevant staff receive AML training at induction and at regular intervals, covering the firm’s procedures, red flags typical of tax and corporate-advisory work, tipping-off, and how to report to the MLRO. The MLRO maintains a training register.

The effectiveness of this policy is subject to principal oversight and, where appropriate, independent compliance review. Supervisory visits by our professional body will be supported fully and transparently.

We will refuse to act, or will terminate an existing relationship, where CDD cannot be completed, where the client will not provide satisfactory source-of-funds evidence, where we are not satisfied as to beneficial ownership, or where continuing would, in the MLRO’s judgement, expose the practice to unacceptable legal or reputational risk. We are not obliged to give a detailed explanation where doing so could constitute tipping off.

We ask clients to treat CDD as part of a regulated professional relationship, not as a formality. Prompt, complete and honest responses protect both the client and the practice. Introducing new shareholders, overseas companies, unusual payment routes or last-minute structuring without documentation will slow or stop the work.

Questions about this policy may be directed to enquiries@centrix-accountants.co.uk. Reports of suspected breaches by the practice should be made to the MLRO at the same address, marked confidential. This policy is reviewed at least annually and after any material change in law, supervision or our service offering.