- Purpose
This Anti-Money Laundering (AML) and Know Your Customer (KYC) Policy outlines Rewardrite Limited’s commitment to preventing the misuse of its services for money laundering, terrorist financing, and other criminal activities. It details the company’s approach to conducting due diligence, verifying client identities, monitoring relationships, and complying with relevant UK legislation.
- Scope
This policy applies to all employees, contractors, and directors of Rewardrite Limited. It also extends to all clients, whether UK-based or international, as well as third parties or agents acting on behalf of clients and any individuals employed or onboarded through the company’s services.
- Legal Framework
Rewardrite Limited adheres to the UK’s AML legal and regulatory framework, including but not limited to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Sanctions and Anti-Money Laundering Act 2018, and relevant guidance provided by HMRC. Where applicable, international standards such as the Financial Action Task Force (FATF) Recommendations will also be considered.
- Definitions
Money laundering refers to the concealment of the origins of illegally obtained money. KYC, or Know Your Customer, is the process of verifying the identity and legitimacy of clients. Customer Due Diligence (CDD) involves understanding the client’s identity, business model, and associated risks. A Politically Exposed Person (PEP) is someone who holds a prominent public position and is considered to present a higher risk of involvement in corruption or bribery.
- Responsibilities
The Legal Compliance Department is responsible for the implementation and oversight of this policy. The Legal Compliance Department acts as the primary point of contact for law enforcement and regulatory bodies, receives internal reports of suspicious activity, and ensures that records of AML and KYC checks are accurately maintained. All employees are responsible for complying with this policy, completing mandatory AML/KYC training annually, and reporting any activity that may be suspicious.
- Customer Due Diligence (CDD)
CDD must be conducted at the start of every client relationship and repeated if there are material changes to the client’s ownership, services provided, or transaction patterns. CDD is also required when suspicion arises, or when doing business with clients from high-risk jurisdictions. Standard CDD involves verifying the identity of individuals using official documents such as a passport or driving licence, along with proof of address such as a recent utility bill. For corporate clients, the company will verify registration with Companies House and identify directors, ultimate beneficial owners (UBOs), and shareholders. All clients will be screened against sanctions lists and databases of PEPs.
- Enhanced Due Diligence (EDD)
Enhanced Due Diligence is applied to high-risk clients, including those based in high-risk third countries, PEPs or individuals associated with PEPs, and clients with complex or opaque ownership structures. EDD involves obtaining additional documentation, verifying the source of funds and wealth, conducting in-depth ongoing monitoring, and frequently reassessing the client’s risk profile.
- Record Keeping
All documentation related to AML and KYC checks will be retained for a minimum of five years following the end of the client relationship. This includes identification documents, service records, internal risk assessments, and any suspicious activity reports.
- Training
All relevant employees will receive AML and KYC training at least once per year. The training will cover relevant legislation, internal procedures for identifying and reporting suspicious activity, and case studies to illustrate typologies of financial crime.
- Suspicious Activity Reporting
Any employee who suspects that a client or transaction may be linked to money laundering or terrorist financing must report the suspicion immediately to the Legal Compliance Department. The Legal Compliance Department will assess the report and determine whether a Suspicious Activity Report (SAR) should be filed with the UK National Crime Agency (NCA). Employees must not inform clients that a SAR has been filed, as doing so constitutes “tipping off” and is a criminal offence.
- Sanctions Compliance
Rewardrite Limited will screen all clients and their associated individuals against UK and international sanctions lists, including those issued by the Office of Financial Sanctions Implementation (OFSI), the United Nations, and the European Union. Any transaction or relationship involving a sanctioned individual or entity will be terminated immediately, and appropriate reports will be made to the relevant authorities.
- Policy Breach and Consequences
Any breach of this policy by employees may result in disciplinary action, including termination of employment. Breaches may also result in criminal liability under UK law. Clients found to be in breach of this policy or posing a significant risk may have their relationship with the company terminated immediately.
Last Updated: April 2025