Hirett Limited (Hirett) recognises the importance of complying with all laws and regulations in relation to combatting money laundering and terrorist financing. Accordingly, Hirett has developed comprehensive measures to ensure that all employees and account holders consistently comply with all relevant laws. It is Hirett’s policy that:
• UK Statutory and regulatory obligations are to be met in full
• Systems and controls are implemented to minimise the risk of Hirett’s services being abused for laundering funds associated with any criminal conduct, as defined by UK legislation, or for terrorist financing. The responsibility to ensure that Hirett does not have any involvement in money laundering or terrorist financing activity falls upon all management and staff.
• Money laundering and terrorist financing risk assessments of Hirett’s services and client base are undertaken. Appropriate policies, procedures and due diligence controls are applied in proportion to that risk.
• Irrespective of seniority or length of service, all employees are required to act with integrity at all times and not engage in fraudulent activity of any kind, even that which may benefit the company.
• The AML related policies are reviewed, at least every 12 months and any changes proposed are approved by the board.
• It is important to note that Hirett’s platform will not deal in CASH.
AML manual
• Approved by the management board and reviewed at least every 12 months. • Follows an enhanced ‘Risk-Based’ approach whereby as per MLR 2017, Hirett has established appropriate risk-sensitive policies and procedures in order to prevent activities related to money laundering and terrorist financing. • All Hirett staff will undergo AML compliance training.
Key compliance components
Transaction Monitoring |
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Sanctions List Screening | Hirett will be performing checks on the names of the potential account holder against known watch-lists and will block those with a > 85% match. The Compliance Officer will then perform a manual check to exclude account holders with false positives. |
Known Watch lists | Hirett will be matching against the following sanctioning bodies: EU Consolidated List of Sanction, HM Treasury Sanctions List, OFAC Sanctions List and UN Sanctions. |
Suspicious Activity Reporting |
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Customer Due Diligence Before opening an account, Hirett is going to perform all the necessary KYC and AML checks on the potential account holder. This would include the following:
Requirement | Corporate | Individual |
Certificate of Incorporation and Memorandum & Articles |
Yes |
No |
Share Register (or equivalent official documents to identify the shareholding structure and ultimate beneficial owners) |
Yes |
No |
Photo ID of Directors & beneficial owner(s) / Individual |
Yes |
Yes |
Residential address verification document of Directors & beneficial owner(s) / Individual |
Yes |
Yes |