Legal document
Anti-Money Laundering Policy
v1.0 draft — final at launch · Pending lawyer review- Version
- v1.0 draft — final at launch
- Last updated
- Pending lawyer review
- Effective
- Live at launch
We follow UK AML regulations. We verify your identity, we monitor transactions for unusual patterns, and we report what we're required to report. We don't ask for documents beyond what regulation requires.
1. Regulatory framework (UK MLR 2017, FCA guidance)
This section sets out the anti-money-laundering laws and guidance we operate under, principally the UK Money Laundering Regulations 2017 and FCA guidance.
{{LEGAL_DRAFT}} — Regulatory-framework statement pending counsel review. Will reference: the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002, applicable FCA guidance, and the firm's risk-based approach to compliance.
2. Customer due diligence (CDD)
This section explains the identity and verification checks we run on every client before and during the relationship.
{{LEGAL_DRAFT}} — Customer due diligence procedures pending counsel review. Will cover: identification and verification of identity, the documents accepted, timing of checks, and the principle that we ask only for what regulation requires — no more.
3. Enhanced due diligence (EDD) for higher-risk clients
This section describes the additional checks applied where a client or situation presents higher money-laundering risk.
{{LEGAL_DRAFT}} — Enhanced due diligence procedures pending counsel review. Will cover: the triggers for EDD (high-risk jurisdictions, complex transactions, PEPs), the additional information collected, and senior-management approval requirements.
4. Politically Exposed Persons (PEPs) screening
This section explains how we identify and handle clients who are politically exposed persons or their close associates.
{{LEGAL_DRAFT}} — PEP screening procedures pending counsel review. Will cover: PEP definition and categories, screening at onboarding and on an ongoing basis, source-of-wealth checks, and senior-management sign-off.
5. Sanctions screening
This section describes how we screen clients and transactions against applicable sanctions lists.
{{LEGAL_DRAFT}} — Sanctions-screening procedures pending counsel review. Will cover: screening against UK (OFSI), UN, and other applicable sanctions lists at onboarding and continuously, and the action taken on a match (freeze and report).
6. Source of funds verification
This section explains when and how we verify where a client's deposited funds come from.
{{LEGAL_DRAFT}} — Source-of-funds procedures pending counsel review. Will cover: the thresholds and triggers for source-of-funds and source-of-wealth checks, the evidence accepted, and the handling of crypto and mobile-money deposits.
7. Ongoing transaction monitoring
This section describes how we monitor account activity for unusual or suspicious patterns over time.
{{LEGAL_DRAFT}} — Transaction-monitoring procedures pending counsel review. Will cover: automated and manual monitoring, the red-flag indicators tracked, deposit/withdrawal pattern analysis, and escalation to the compliance function.
8. Suspicious activity reporting
This section explains our obligation to report suspicious activity and that we report what we are legally required to report.
{{LEGAL_DRAFT}} — Suspicious activity reporting procedures pending counsel review. Will cover: internal reporting to the MLRO, submission of Suspicious Activity Reports to the National Crime Agency, the prohibition on tipping-off, and the legal protections for reporting.
9. Record-keeping requirements
This section sets out how long we retain identity and transaction records to meet our AML obligations.
{{LEGAL_DRAFT}} — Record-keeping procedures pending counsel review. Will cover: retention of CDD records and transaction history for the regulatory minimum (generally five years after the relationship ends), secure storage, and the interaction with data-protection retention rules.
10. Staff training and compliance
This section describes how staff are trained to recognise and act on money-laundering risk.
{{LEGAL_DRAFT}} — Staff-training procedures pending counsel review. Will cover: induction and ongoing AML training, the frequency of refreshers, and the documentation of training completion.
11. Cooperation with authorities
This section confirms that we cooperate with regulators and law-enforcement requests as required by law.
{{LEGAL_DRAFT}} — Authority-cooperation statement pending counsel review. Will cover: responding to lawful requests from the FCA, NCA, OFSI, and courts, and the circumstances under which client information is disclosed.
12. Compliance officer contact
This section tells clients how to reach our compliance function, including the Money Laundering Reporting Officer.
{{LEGAL_DRAFT}} — Compliance-contact details pending counsel review. Will include: the named MLRO (or compliance function), and the contact route (compliance@tfcglobalmarkets.com), confirmed at launch.
This document is in draft pending review by UK financial services counsel. Sections marked with an amber Draft badge contain placeholder text and are not final. Finalized versions go live before we open to traders. Questions: compliance@tfcglobalmarkets.com.