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Keyplus Group Ltd – Money Laundering Regulations Policy

 

  1. Money laundering is a process where money obtained, as a result of a crime, is used to pay for services or goods. Although the term ‘money laundering’ is usually associated with organised criminal activities, it can include a suspicion that someone you know, or know of, is benefiting financially from dishonest activities, e.g. non-payment of income tax.
  1. People involved in handling criminal property look for ways to secure and safeguard the proceeds of their criminal activities. Although other ways exist such as Cryptocurrencies and ‘Cyber-Payments’, cash is the mainstay of criminal transactions, being the most reliable and flexible, and having little or no audit trail.
  1. Criminals often transport cash out of the UK using couriers, usually through airports, to pay into banks overseas. They use this money to purchase property abroad, or to pay to their families.
  1. In the UK, the most popular method of money laundering is thought to be the purchase of property and online trading in shares or Cryptocurrencies, followed by investment in front companies, or high cash turnover businesses (often legitimate businesses), or by funding a lifestyle. After property, the most significant assets bought by criminals are jewellery, artwork, antiques, cars and boats.
  1. Criminals also invest cash in financial products with a view to selling them quickly (if necessary at a loss). Criminals also use trusts, online platforms and third-party intermediaries to launder money because of their secretive nature and flexibility, trying to hide identities.
  1. Criminals use ‘layering’ to confuse any audit trail. This involves passing transactions through several stages, often eventually banking the proceeds of business income and transferring the money overseas to a country whose regulatory regime is weaker.
  1. Examples of money laundering can include:

– large cash payments;

– asking for cash refunds on credit card payments; or

– overpaying bills then asking for cash refunds

– sinking money into online trading and investments.

  1. There are three main offences:

– Concealing: knowing or suspecting a case of money laundering but concealing or disguising its existence.

– Arranging: becoming involved in an arrangement to launder money or assisting in money laundering for a third party.

– Acquisition, use or possession: benefiting from money laundering by acquiring, using or possessing the property concerned.

  1. There is also a ‘third party’ offence – failure to disclose one of the three main offences detailed above.
  1. None of these offences are committed if:

– the persons involved did not know or suspect that they were dealing with the proceeds of crime; or

– a report of the suspicious activity is made promptly to any Money Laundering Reporting Officer

Or the Police.

  1. Money laundering offences may be tried at a magistrate’s court or in the Crown Court, depending on the severity of the suspected offence. Trials at a magistrate’s court can attract fines of up to £5,000, up to 6 months in prison, or both. In a Crown Court, fines are unlimited and with possible prison sentences of between 2 to 14 years.

Keyplus Group Ltd have adopted the following policy in relation to its website and trading platform;

  1. All individuals or companies or partnerships or individual investors, give a specific undertaking that they are not involved in any money laundering activities.
  1. Any new investor wishing to invest or transact over £5,000 (five thousand Pounds) value of Fiat cash or Cryptocurrency must provide the following information before they will be allowed to transact or invest;

– the supply of a valid bank account in their name, for payments to and from Keyplus Group Ltd or any other third party via the website, platform or exchange.

– supply a valid photo ID (such as photo driving licence, passport or national identity card) together with a copy of a bank statement, utility bill (not mobile phone account) or HRMC letter in their own name and showing the address they register upon the platform with.

  1. Such proof of ID shall be treated with a high degree of security and shall be subject to our Privacy & Data Handling Policy.
  1. We shall retain such copy on file for a period up to 5 (five) years. This shall be private unless a valid demand for disclosure is made by a competent, relevant authority such as the Court, the Police, HRMC, the IRS or the Benefits Agency.
  1. We will remain vigilant and report any suspicions to help prevent and detect money laundering, in an effort to keep our platform safe and protect our members from any abuse or harm whilst trading with us.

 

This policy complies with;

 

– the Proceeds of Crime Act 2002 (POCA), as amended by The Serious Organised Crime and Police Act 2005 (SOCPA). POCA provides for civil recovery of the proceeds from crime.

– the Terrorism Act 2000 (TA 2000) (as amended by the Anti-Terrorism Crime and Security Act 2001 and the Terrorism Act 2006). The TA relates to the proceeds of terrorism and terrorist financing.

– the Money Laundering Regulations 2007. These are concerned with measures to restrict the opportunities for money laundering. POCA and TA 2000 contain offences which may be committed by individuals or entities. The 2007 Regulations deal with the systems and controls which businesses are

required to have in place and contain obligations to be vigilant and report any suspected infringements.

 

This policy was last updated on 1st March 2018.

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