AML Policy

1. Introduction

Heritage Assets is committed to the highest standards of Anti-Money Laundering (AML) compliance and requires all employees, managers, and associated persons to follow these standards to prevent the use of our services for money laundering or terrorist financing purposes.

This policy establishes the framework for our AML program and outlines the procedures we implement to detect, prevent, and report suspicious activities that might be related to money laundering or terrorist financing.

2. Regulatory Framework

Heritage Assets complies with all applicable AML laws and regulations, including but not limited to:

• The Financial Action Task Force (FATF) Recommendations
• The UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
• The Proceeds of Crime Act 2002
• The Terrorism Act 2000
• The EU 5th Anti-Money Laundering Directive
• Other relevant local and international regulations

3. Key Principles

Our AML policy is based on the following key principles:

• Risk-based approach to customer due diligence
• Know Your Customer (KYC) procedures
• Ongoing monitoring of transactions and customer relationships
• Reporting of suspicious activities
• Record keeping
• Staff training and awareness
• Regular independent audits and reviews

4. Customer Due Diligence (CDD)

Heritage Assets conducts appropriate customer due diligence measures when:

• Establishing a business relationship
• Carrying out occasional transactions above specified thresholds
• There is suspicion of money laundering or terrorist financing
• There are doubts about previously obtained customer identification data

Our standard CDD measures include:

• Identifying the customer and verifying their identity using reliable, independent source documents, data, or information
• Identifying the beneficial owner and taking reasonable measures to verify their identity
• Understanding the purpose and intended nature of the business relationship
• Conducting ongoing due diligence on the business relationship

5. Enhanced Due Diligence (EDD)

Enhanced due diligence measures are applied in higher-risk scenarios, including:

• Business relationships or transactions with persons from high-risk countries
• Politically Exposed Persons (PEPs) and their family members or close associates
• Complex or unusually large transactions
• Unusual patterns of transactions with no apparent economic or lawful purpose
• High-risk business relationships or products

EDD measures may include:

• Obtaining additional information on the customer and beneficial owner
• Obtaining information on the source of funds and wealth
• Obtaining senior management approval for establishing or continuing the business relationship
• Conducting enhanced monitoring of the business relationship
• Requiring the first payment to be made through an account in the customer's name with a bank subject to similar CDD standards

6. Transaction Monitoring

Heritage Assets maintains systems and controls to monitor customer transactions for potentially suspicious activity. Our monitoring includes:

• Automated screening against sanctions and PEP lists
• Detection of unusual transaction patterns
• Identification of transactions that deviate from the expected pattern of activity
• Monitoring of high-risk customers and transactions
• Regular review of monitoring thresholds and parameters

7. Suspicious Activity Reporting

Heritage Assets has procedures in place for the reporting of suspicious activities:

• All staff are required to report suspicious activities to the designated Money Laundering Reporting Officer (MLRO)
• The MLRO evaluates all internal reports and determines whether a Suspicious Activity Report (SAR) should be filed with the relevant authorities
• SARs are filed promptly when there is knowledge or suspicion of money laundering or terrorist financing
• All internal and external reports are kept confidential
• Tipping off is strictly prohibited

8. Record Keeping

Heritage Assets maintains records of:

• All customer identification documents obtained during CDD
• All transactions carried out by customers
• All internal and external suspicious activity reports
• AML training records
• Decisions made in relation to suspicious activity

Records are kept for at least five years after the end of the business relationship or the date of the occasional transaction.

9. Staff Training and Awareness

Heritage Assets ensures that all relevant staff receive appropriate AML training:

• New employees receive AML training as part of their induction
• Regular refresher training is provided to all staff
• Specialized training is provided to staff in higher-risk roles
• Training covers legal and regulatory requirements, company policies and procedures, and recognition of suspicious activities
• Training effectiveness is regularly assessed

10. Independent Audit and Review

Heritage Assets conducts regular independent audits of its AML program to:

• Assess compliance with applicable laws and regulations
• Evaluate the effectiveness of AML policies and procedures
• Identify areas for improvement
• Ensure that corrective actions are implemented

11. Sanctions Compliance

Heritage Assets complies with all applicable sanctions regimes:

• Customers are screened against relevant sanctions lists
• Transactions are screened to prevent dealings with sanctioned countries, entities, or individuals
• Potential sanctions matches are investigated promptly
• Confirmed sanctions matches are reported to the relevant authorities

12. Risk Assessment

Heritage Assets conducts regular risk assessments to identify and assess money laundering and terrorist financing risks:

• Customer risk factors (e.g., high-risk jurisdictions, PEPs, complex ownership structures)
• Product, service, and transaction risk factors (e.g., anonymity, cross-border transfers)
• Delivery channel risk factors (e.g., non-face-to-face relationships)
• Geographical risk factors (e.g., countries with weak AML controls)

Risk assessments are documented and used to inform our AML policies and procedures.