By using this site you agree to the use of cookies for analytics and personalized content. Learn more
Accept and continue Deny
Get in touch
Sign In

AML/KYC

AML POLICY

Last Updated: 11 Mar 2025

 

The Service Provider is fully committed to complying with all relevant laws and regulatory requirements in the international fight against money laundering, terrorist financing and proliferation financing. This AML Policy establishes minimum standards for anti-money laundering, counter-terrorist financing and counter-proliferation financing which the Service Provider complies to.

Our Website is: https://www.sterliqpay.co.uk/ 

Your Service Provider is: STERLIQPAY LTD, company number: 16286931, address: Northway House 257-258 Upper St, Highbury & Islington, London, United Kingdom, N1 1RU.

Our contact e-mail address is: support@sterliqpay.co.uk 

 

The terms mentioned herein, if not explicitly stated otherwise, have the same meaning as defined in the Terms and Conditions.

  1. OBJECTIVE OF THIS AML POLICY

    1. The policy applies to all directors and staff, including permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the Service Provider and has been created to ensure that the staff deal with the area that this Policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

  2. REGULATORY FRAMEWORK

    1. The Service Provider adheres to the following laws and regulations, including but not limited to:

      1. Proceeds of Crime Act 2002 (POCA);

      2. The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017);

      3. The Terrorism Act 2000;

      4. The Financial Action Task Force (FATF) Recommendations;

      5. Regulations imposed by the Financial Conduct Authority (FCA);

      6. The UK Sanctions and Anti-Money Laundering Act 2018.

The Service Provider ensures compliance with applicable local and international AML laws and cooperates with law enforcement authorities whenever necessary.

  1. WHAT IS MONEY LAUNDERING? 

Money laundering is a process through which criminals seek to conceal the true origin, ownership and/or purpose of the proceeds of any criminal activity in order to give the impression that these proceeds originated from legitimate sources. Generally, money laundering occurs in three stages:  

 

  1. Placement. Cash first enters the financial system at the "placement" stage, where the cash generated from criminal activities is converted into monetary instruments. Such monetary instruments could be: money orders or traveler’s checks, deposited into accounts at financial institutions, dividing the cash into smaller amounts and make various deposits into one or more accounts at one or more banks; Customer opens several accounts in different names at different institutions; employ or persuade others to deposit funds for them; purchasing goods such as jewelry, art and other assets with a view to reselling them at a later date; making deposits with the help of employees of the relevant financial institution.  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.  

  2. Layering. At the "layering" stage, the funds are transferred or moved into other accounts or other financial institutions to further separate the money from its criminal origin. As example: Selling assets or switching to other forms of investment; transferring money to accounts at other financial institutions; wiring transfers abroad (often using shell companies); depositing cash in overseas banking systems. 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.

  3. Integration. Once the origin of the funds has been obscured, a criminal is able to make the funds reappear as legitimate funds or assets.  At the "integration" stage, the funds are reintroduced into the economy and used to purchase legitimate assets or to fund other criminal activities or legitimate businesses, for example - an inheritance, loan payments, asset sales abroad. 

  1. WHAT IS TERRORIST FINANCING?

    1. Terrorist financing may not involve the proceeds of criminal conduct, but rather an attempt to conceal either the origin of the funds or their intended use, which could be for criminal purposes. Legitimate sources of funds are a key difference between terrorist financiers and traditional criminal organizations.  

    2. In addition to charitable donations, legitimate sources include foreign government sponsors, business ownership and personal employment. Although the motivation differs between traditional money launderers and terrorist financiers, the actual methods used to fund terrorist operations can be the same as or similar to methods used by other criminals to launder funds. Funding for terrorist attacks does not always require large sums of money and the associated transactions may not be complex.  

    3. It is important to note distinct characteristics of terrorist financing that can make it even more difficult to detect than money laundering:  

      1. Terrorists may finance attacks through simple transactions that involve a relatively small amount of money and may be indistinguishable from normal activity;  

      2. Terrorists may finance attacks using both unlawful and lawful sources of funds, including charitable donations, unlike money laundering where the source of funds is always unlawful; and  

      3. In terrorist financing, the focus is primarily on the usage of the funds, whether lawfully or unlawfully derived.  

  2. RISK ASSESSMENT

    1. The Service Provider adopts a risk-based approach (RBA) to ensure adequate controls are in place to mitigate potential ML/TF/PF risks. This includes:

      1. Assessing customer risk profiles.

      2. Implementing enhanced due diligence (EDD) for high-risk customers.

      3. Monitoring transactions for unusual patterns or red flags.

  3. STAFF RESPONSIBILITY

    1. All members of staff are at risk of committing a criminal offence if they assist in a criminal transaction by missing the warning signs. The Service Provider does not provide Services in any way to anonymous Customers or Customers whose identity has not been established and verified in strict abidance with our internal rules and regulations.

    2. The Service Provider does not engage in business activities with shell corporations and shell banks.

    3. In line with PCMLTFA and industry-wide best practices, the Service Provider identifies its potential Customers and their ultimate beneficial owners (UBOs), verifies their identities and performs standard (CDD) or enhanced (EDD) due diligence before the start of a business relationship.  

  4. COMPLIANCE OFFICER/MONEY LAUNDERING REPORTING OFFICER

    1. The Service Provider designated a compliance officer (“CO”).

    2. The principal function of the CO is to act as the focal point within the Service Provider for the oversight of all activities relating to the prevention and detection of ML/TF and to provide support and guidance to individuals with the objective of ensuring that ML/TF risks are adequately managed. In particular, the CO should assume responsibility for developing and/or continuously reviewing Service Provider’s AML compliance framework (including this Policy) to ensure it remains up-to-date, effective and consistent with current statutory and regulatory requirements, as well as reflecting the risk profile of Customers.

    3. The Service Provider’s CO is also its designated money laundering reporting officer (“MLRO”). Any individual having knowledge or suspicion of money laundering must disclose that development to the MLRO.

    4. The MLRO should play an active role in the identification and reporting of suspicious transactions. Principal functions include:

      1. reviewing all internal reports from individuals and, in light of all available relevant information, determining whether or not it is necessary to make a report to the Regulator;

      2. maintaining all records related to such internal reviews;

      3. providing guidance on how to avoid “tipping off” if any disclosure is made; and

      4. acting as the main point of contact with the Regulator, law enforcement, and any other competent authorities in relation to ML/TF issues.

  5. AML MEASURES APPLICABLE BY THE SERVICE PROVIDER

    1. We take the utmost care in ensuring that all our customers are compliant with Anti-Money Laundering (AML) regulations. To this end, our AML procedures include proper identification and verification of each customer, periodical AML training for staff, transactions monitoring and risk-based analysis, as well as procedures for reporting suspicious activity internally and to relevant law enforcement authorities. 

    2. We also establish and maintain a risk-based customer due diligence program which includes enhanced due diligence for those customers who present higher risks. If we find any discrepancies, we are obliged to reject the customer's documents, close the Account and terminate the business relationship.