1. INTRODUCTION:
This policy sets out the principles and procedures adopted by Hashtag Ltd to prevent and combat money laundering and terrorist financing. It complies with UK regulations and regulatory requirements, including:
- Money Laundering Regulations 2017 (MLR 2017);
- Financial Services and Markets Act 2023;
- Terrorism Act 2000;
- Proceedings of Crime Act 2002;
- FCA Handbook , with particular reference to SYSC and FCTR.
1.1 Purpose of the Policy
Hashtag Ltd works with regulated and licensed partners to ensure all transactions comply with applicable AML and KYC regulations.
1.2 Applicability
This policy applies to:
- All customers of Hashtag Ltd;
- All services offered, including money transfers and currency exchange;
- All transactions, regardless of their nature or amount.
2. Customer Due Diligence (CDD) Process:
2.1 Identity Verification
We require customers to provide valid documents to verify their identity, including:
- A photo ID (passport, UK driving licence, EU ID card);
- Proof of residency (utility bill or bank statement no older than three months);
- Any additional documents, based on the level of risk or applicable regulations.
2.2 Verification Levels
2.2.1 Standard Verification
Applies to transactions up to £1,000. Requires:
- Identity document;
- Proof of residency.
2.2.2 Advanced Verification
Required for:
- Transactions over £1,000;
- Customers identified as high risk;
- Suspicious activity reported by monitoring systems.
2.2.3 Enhanced Due Diligence (EDD)
Mandatory in the following cases:
- Customers classified as Politically Exposed Persons ( PEPs );
- Transactions with high-risk countries;
- Complex or unusual operations.
3. Transaction Monitoring:
3.1 Monitoring System
We use automated and manual tools for continuous monitoring of transactions, in order to:
- Identify anomalies and suspicious patterns;
- Detect activities that exceed predefined thresholds;
- Ensure compliance with applicable regulations.
3.2 Thresholds and Triggers
Monitoring is based on:
- Single transaction and cumulative limits;
- Abnormal behavioral patterns;
- Geographic indicators relating to high-risk countries.
4. Risk assessment:
4.1 Risk Criteria
Factors taken into consideration include:
- Customer profile: activity, residence, declared income;
- Nature of the transaction: frequency, amount, complexity;
- Country or geographic area: transactions to/from high-risk jurisdictions;
- Distribution channel: online or offline transactions.
4.2 Risk Categories
- Low risk : customers with simple and regular transactions;
- Medium risk : less frequent but not unusual activities;
- High risk : complex operations or customers from high-risk countries;
- Unacceptable risk : situations where money laundering or illegal activities are suspected.
5. Reporting and Data Retention:
5.1 Reporting Suspicious Activity
Any suspicious activity is reported to the Money Laundering Reporting Officer (MLRO) via a Suspicious Activity Report (SAR). Reports must be made promptly and documented.
5.2 Document Retention
Customer and transaction data is retained for 5 years from the date of the last transaction or account closure;
Documents are stored in secure electronic format and accessible only to authorized personnel.
6. Training and Compliance:
6.1 Staff Training
All employees receive specific training on:
- Recognition of suspicious activity;
- AML and KYC regulations;
- Use of monitoring systems.
The training is updated annually and documented.
6.2 Audits and Reviews
- Quarterly internal audits to ensure compliance with procedures;
- Annual external reviews conducted by independent consultants;
- Detailed reports are shared with the board of directors.
7. Sanctions and Checklists:
7.1 Screening of Sanctions Lists
All customers are checked for:
- UK Sanctions List;
- UN Sanctions List;
- EU Sanctions List;
- OFAC Lists (Office of Foreign Assets Control).
7.2 Screening Procedure
- Screening occurs during onboarding and periodically;
- Alerts generated are handled in a timely and documented manner.
8. Roles and Responsibilities:
8.1 MLRO (Money Laundering Reporting Officer)
- Responsible for overseeing AML/KYC policies;
- Assessment and reporting of suspicious activities;
- Supervision of staff training.
8.2 Compliance Team
- Performs daily checks and supports the MLRO;
- Monitor transactions and update records;
- Conducts internal investigations when necessary.
9. Privacy and Security:
Hashtag Ltd ensures the confidentiality of all information collected as part of AML and KYC procedures, fully complying with data protection regulations.
10. Policy Updates:
This policy is reviewed annually and updated to reflect any regulatory or operational changes. Any significant changes will be communicated internally and posted on our website.
11. Contacts::
For any questions or concerns, please contact:
Compliance Team: compliants@hashtagwallets.com