| NAME OF POLICY | ANTI-MONEY LAUNDERING |
| APPROVAL AUTHORITY | RISK COMMITTEE, BOARD |
| ACCOUNTABLE EXECUTIVE | CHIEF EXECUTIVE OFFICER |
| POLICY CUSTODIAN | RISK & COMPLIANCE MANAGER |
| APPROVAL DATE | |
| POLICY OWNER | CHIEF EXECUTIVE OFFICER |
| LAST REVIEW DATE | February 2026 |
| NEXT REVIEW DATE | February 2027 |
| VERSION | 1.02 |
Table of Contents
1. Policy Statement ………………………………………………………………………………………………………..3
2. Anti-Money Laundering Procedures for Klapton Insurance Company Limited ………….3
1.0 Customer Due Diligence ………………………………………………………………………………………….4
2.0 Risk Assessment and Ongoing Monitoring ………………………………………………………………5
3.0 Internal Controls and Communication …………………………………………………………………….6
4.0 Monitoring and Managing Compliance ……………………………………………………………………6
5.0 Suspicious Activity Reporting……………………………………………………………………………………6
6.0 Record-Keeping ……………………………………………………………………………………………………….6
7.0 Training ……………………………………………………………………………………………………………………6
Signing Page ………………………………………………………………………………………………………………….7
POLICY STATEMENT
These are the Anti-Money Laundering (AML) Policies and Procedures adopted by Klapton Insurance Company Limited (hereafter referred to as “KIC”) in compliance with KIC’s internal
policies and regulatory obligations and the business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism
financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.
The purpose of implementing anti-money laundering and counter-terrorist financing (AML/CFT) measures is to stop criminals and terrorists from abusing the financial system.
Through effective implementation of these measures, KIC can help trace and stop the financial flows linked to serious crime and terrorism and make society safer.
Some of the activities in mitigating this risk will be:
- The identities of all new and existing clients will be verified to a reasonable level of certainty
- A risk-based approach will be taken to the monitoring of client tax and accounting affairs
- Any suspicious activity will be reported, and all AML activities recorded
- An assigned Money Laundering Reporting Officer (MLRO) or AML Compliance Officer, in consultation with the board of directors, will be appointed to coordinate the money laundering policies and procedures of the business.
- All staff members that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.
- An accurate record, containing the names and signatures of members of the staff that have read the anti-money laundering policy and procedures of this practice, will be kept at all times.
| MEMBER OF STAFF | SIGNATURE | DATE |
ANTI-MONEY LAUNDERING PROCEDURES FOR KIC
1. CUSTOMER DUE DILIGENCE
The business has established a Know-Your-Client (KYC) policy to ensure that the identities of all new and existing clients are verified to a reasonable level of certainty.
This will include all individual clients, all directors and shareholders with a stake holding of 10% or more of client companies, all partners of client partnerships and every board member of client charity organisations. Identities will be verified either online or face-to face or by a combination of both.
The following documentation may be presented by the individual as follows;
Documents to be submitted in person
- Either a passport, driver’s license, or government issued document featuring a matching photograph of the individual, and a full name and date of birth matching those provided.
- An original recent utility bill, or government issued document with the same and address matching those provided by the individual.
Documents that can be presented without physical presence
- Any government issued document that provides the date of birth, National Identity or Tax number or other such government identifier.
- Other forms of identity confirmation, such as evidence of a long-standing relationship with the client, or a letter of assurance from independent and reliable persons or organisations, who have dealt with the client for some time, may also provide a reasonable level of certainty.
If the business fails to verify the identity of a client with reasonable certainty, it will not establish a business relationship or proceed with the transaction. If a potential or existing client either refuses to provide the information described above when requested, or appears to have intentionally provided misleading information, the business shall refuse to commence a business relationship or proceed with the transaction requested.
2. RISK ASSESSMENT AND ONGOING MONITORING
The business shall take a risk-based approach in monitoring the financial activities of its clients.
The business will actively not accept high-risk clients that are identified as follows:
- Clients with businesses that handle large amount of cash (i.e., involving USD 18,000 or more per transaction, or the Great Britain Pound Sterling GBP equivalent) or complex unusually large transactions.
- Clients with larger one-off transactions, or several transactions carried out by the same customer within a short space of time.
- Clients with complex business ownership structures with the potential to conceal underlying beneficiaries.
- Clients based in or conducting business in or through, a high-risk jurisdiction, or a jurisdiction with known higher levels of corruption, organized crime, or drug production/distribution.
- Situations where the source of funds cannot be easily verified.
- Unusual patterns of transactions that have no apparent economic or visible lawful purpose.
- Money sent to or received from areas known to have high levels of criminality or terrorist activity.
The business will conduct ongoing monitoring of business relationships with customers, to ensure that the documents, date, or information held evidencing the customer’s identity are kept up to date.
The following are examples of changes in a client’s situation that may be considered suspicious:
- A sudden increase in business from an existing customer without adequate explanation;
- Uncharacteristic transactions which are not in keeping with the customer’s known activities;
- Peaks of activity at particular locations or at particular times;
- Unfamiliar or untypical types of customers or transactions.
Whenever there is cause for suspicion, the client will be asked to identify and verify the source or destination of the transactions, whether they be individuals or company beneficial owners.
No action need to be taken if there is no cause for suspicion.
3. INTERNAL CONTROLS AND COMMUNICATION
Internal controls and communication are not applicable as the business will only have one person involved in client compliance.
4. MONITORING AND MANAGING COMPLIANCE
The appointed AML Compliance Officer (equivalent to the Money Laundering Reporting Officer) will on a quarterly basis monitor the following procedures to ensure they are being carried out in accordance with the AML policies and procedures of the business:
- client identity verification;
- reporting suspicious transactions;
- record keeping.
The AML Compliance Officer will also monitor any developments in AML and the requirements of the AML supervisory body. Changes will be made to the AML policies and procedures of the business, when appropriate, to ensure compliance.
5. SUSPICIOUS ACTIVITY REPORTING
A Suspicious Activity Report (SAR) will be made to the relevant authority as soon as there is knowledge or suspicion that criminal proceeds and/ or a money laundering offence is being, has been or is about to be committed.
The AML Compliance Officer will be responsible for deciding whether or not the suspicion of illegal activity is great enough to justify the submission of a SAR.
6. RECORD-KEEPING
Records of all identity checks will be maintained for up to 10 years after the termination of the business relationship or 10 years from the date when the transaction was completed. The business will ensure that all documents, data, or information held in evidence of customer identity is kept up to date.
All records will be handled in confidence, stored securely, and will be capable of being retrieved without undue delay.
7. COMPLIANCE
KIC will comply with any directives issued to it by the Supervisory Authority with respect to money laundering activities.
8. REPORTING OFFICER
KIC will designate an officer in each branch or local office to be responsible for reporting all transactions suspected of being related to money laundering to the relevant authorities.
9. TRAINING
KIC shall, with the assistance of the relevant institution, provide employees with training on the enactments and regulations on money laundering, in mechanisms for preventing money laundering, and in the recognition and handling of business transactions carried out by or on behalf of any person who is or appears to be engaged in money laundering.
All affected employees should be trained on their responsibilities in relation to money laundering transactions.
