Anti-Money Laundering (AML) Policy for Agency Operations
Effective Date: 3.03.2025
LUXE AVENUE LTD
1. Introduction
LUXE AVENUE LTD, as an agent engaged in wholesale procurement and supply of goods from leading global brands, is committed to complying with international anti-money laundering (AML) and counter-terrorist financing (CFT) standards. The company adheres to the regulations of the United Kingdom, the European Union, and the Financial Action Task Force (FATF) to ensure financial transparency and security in all transactions.
This policy aims to prevent the use of LUXE AVENUE LTD’s services for money laundering, fraudulent activities, or terrorist financing, while protecting clients, partners, and the company from legal and financial risks.
2. AML/CFT Compliance Principles
LUXE AVENUE LTD is committed to:
✔ Implementing strict Know Your Customer (KYC) procedures.
✔ Identifying and rejecting suspicious transactions.
✔ Ensuring financial transparency in all agency operations.
✔ Cooperating with regulatory and law enforcement authorities as required.
3. KYC (Know Your Customer) Procedures
3.1. Client and Partner Due Diligence
Before engaging in business relationships, LUXE AVENUE LTD conducts mandatory due diligence on all counterparties, including:
✔ Identity verification (passport/ID for individuals, business registration documents for legal entities).
✔ Proof of address (bank statement, utility bill).
✔ Source of funds verification (for high-value transactions).
✔ Business references from other counterparties (if applicable).
3.2. High-Risk Categories
LUXE AVENUE LTD applies enhanced due diligence (EDD) for:
⚠ Clients from jurisdictions with high financial crime risks or sanctions.
⚠ Politically Exposed Persons (PEP).
⚠ Clients using complex or unusual payment structures.
4. Transaction Monitoring and Detection of Suspicious Activity
4.1. Red Flags for Suspicious Transactions
The company monitors financial transactions and identifies red flags, such as:
🚩 Payments that do not match the client’s normal business activities.
🚩 Layered transactions moving through multiple jurisdictions.
🚩 Attempts to bypass standard verification procedures.
🚩 Incomplete or fraudulent client documentation.
4.2. Actions in Case of Suspected Money Laundering
LUXE AVENUE LTD reserves the right to:
❌ Reject or block transactions that raise concerns.
❌ Request additional documentation for further verification.
❌ Report suspicious activity to regulatory authorities, if required.
4.3. Enhanced Due Diligence (EDD) for High-Risk Transactions
🔹 For transactions that meet one or more red flag criteria, LUXE AVENUE LTD applies Enhanced Due Diligence (EDD) measures before processing.
🔹 This may include:
Verification of the source of funds and wealth.
Additional identity checks and documentation requests.
Monitoring past transactions and payment patterns.
Direct contact with the client for clarification.
4.4. Differentiation Between AML and Fraud Prevention
🔹 The AML Policy focuses exclusively on financial crimes, such as money laundering, illicit transactions, and the use of falsified financial documents.
🔹 The Fraud Prevention Policy addresses commercial fraudulent schemes, including fake invoices, fraudulent supply chains, and counterfeit goods.
🔹 If a case involves both financial crime and commercial fraud, LUXE AVENUE LTD may escalate the case to both financial regulators and law enforcement agencies for further investigation.
4.5. Internal Reporting and Escalation Procedures
🔹 All employees are required to report any suspected money laundering to the Compliance Officer immediately.
🔹 The Compliance Officer will:
Review and assess the transaction within 24 hours.
Determine whether escalation to regulatory authorities is necessary.
Maintain records of all reported transactions for at least 5 years.
🔹 Employees who knowingly fail to report suspicious activity may face disciplinary actions, including termination.
5. Cooperation with Regulators and Authorities
LUXE AVENUE LTD:
✔ Reports suspicious transactions to the UK’s National Crime Agency (NCA).
✔ Maintains client and transaction records for at least 5 years.
✔ Cooperates with banks and financial institutions in ensuring AML compliance.
6. Employee Training and AML Awareness
LUXE AVENUE LTD already follows AML procedures and is in the process of implementing a structured AML training program to enhance employee awareness.
6.1. Current AML Measures
✔ All employees adhere to internal AML regulations and KYC protocols.
✔ Management oversees AML compliance and transaction monitoring.
6.2. Planned AML Training Program
LUXE AVENUE LTD is developing an AML training program that will cover:
✔ International FATF standards and compliance requirements.
✔ Practical case studies on identifying suspicious activities.
✔ Collaboration with financial institutions and regulators.
The program will be implemented gradually, considering the company’s operations and evolving regulatory requirements.
6.3. Monitoring and Accountability
✔ Employees receive guidelines on AML compliance and procedures.
✔ Until formal training is fully implemented, the company applies strict internal AML controls.
✔ Non-compliance with AML standards may result in disciplinary actions, including termination.
7. Responsibility of Clients and Partners
❌ Providing false documentation or attempting to circumvent KYC requirements will result in the immediate termination of the business relationship.
❌ If money laundering violations are detected, relevant information will be reported to financial regulators and law enforcement agencies.
8. Policy Review and Updates
LUXE AVENUE LTD reserves the right to update this policy as required to remain compliant with UK, EU, and FATF regulations.
9. Contact Information
For any questions regarding this policy, please contact:
📍 LUXE AVENUE LTD
Address: 9 Acorn Close, Maidstone, Kent, United Kingdom, ME16 8FX
✉ Email: [email protected]
🌐 Website: luxe-avenue.store