Anti-Money Laundering (AML) Policy

Anti-Money Laundering (AML) Policy - Absolute Financial Software Solution (AFSS) Limited

1. Introduction

   Absolute Financial Software Solution (AFSS) Limited is committed to the highest standards of anti-money laundering (AML), counter-terrorist financing (CTF), and financial crime prevention. We are fully aligned with the UK Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, and other applicable laws and regulations. AFSS adopts a zero-tolerance approach to money laundering, terrorist financing, and any activity that facilitates criminal conduct.

2. Objective

   This policy outlines AFSS’s framework to prevent and detect any attempt to use the Company for money laundering, terrorism financing, or other illicit activities. It also details the responsibilities of employees, partners, and contractors in identifying and reporting suspicious activity.

3. Scope

   This policy applies to all employees, contractors, partners, and consultants of AFSS. It covers all business units, software solutions, consultancy services, and interactions with clients and third parties.

   4. Legal and Regulatory Compliance

   AFSS complies with all relevant AML and CTF regulations in jurisdictions where it operates. This includes:

   • Conducting due diligence and Know Your Customer (KYC) checks.

   • Maintaining proper records of client identification and transactional activity.

   • Reporting suspicious activity to the appropriate authorities.

   5. Risk-Based Approach

   AFSS adopts a risk-based approach to AML compliance. This involves:

   • Risk assessment of clients, markets, and services.

   • Enhanced due diligence for higher-risk clients or transactions.

   • Continuous monitoring and review of risks across the business.

   6. Customer Due Diligence (CDD)

   AFSS implements appropriate CDD procedures before entering any business relationship, including:

   • Verifying the identity of clients and beneficial owners.

   • Understanding the nature and purpose of the business relationship.

   • Conducting ongoing monitoring of client activity.

   Where enhanced due diligence is required (e.g., politically exposed persons or high-risk countries), additional scrutiny will be applied.

   7. Record Keeping

   All AML-related documents, including KYC data, transaction records, and communications, will be retained for a minimum of five years in compliance with applicable regulations.

   8. Reporting Obligations

   All employees are required to report any knowledge or suspicion of money laundering activity to the designated AML Compliance Officer without delay. Reports will be reviewed and, if appropriate, escalated to the UK Financial Intelligence Unit (FIU) via a Suspicious Activity Report (SAR).

   9. Staff Training

   AFSS ensures that all relevant personnel are trained on AML compliance, including how to recognise and report suspicious activity. Training is regularly updated to reflect changes in legislation and emerging risks.

   10. Monitoring and Review

   This policy is reviewed at least annually and updated as necessary to reflect changes in regulations, risk assessments, or business operations. Internal audits and compliance checks are conducted to ensure the effectiveness of AML controls.

   Contact Details
   For any AML-related inquiries or to report suspicious activity, please contact:

   Office Telephone: +44 208 145 3355
   Email: info@afssolution.com
   Address: Ability House, 121 Brooker Road, Waltham Abbey, EN9 1JH, United Kingdom

   Approved by: AFSS Directors
   
   Date: July 2025

AFSS Anti-Money Laundering (AML) Policy

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