Anti-Money Laundering Policy

1. Policy Statement

Keane International Legal Consultancy LLP ("KILC") is committed to the highest standards of anti-money laundering (AML) compliance and requires all members, employees, contractors, and agents to adhere to these standards in preventing the use of our services for money laundering or terrorist financing purposes.

KILC maintains a zero-tolerance approach to money laundering and terrorist financing. We are committed to acting with integrity, transparency, and in accordance with all applicable UK laws and regulations. Any breach of this policy will be treated as a serious disciplinary matter and may result in criminal prosecution.

2. Scope

This policy applies to all members, partners, employees, contractors, and agents of KILC. It covers all business relationships and one-off transactions, regardless of value, where there is a risk of money laundering or terrorist financing.

The policy applies to all service areas provided by KILC, including but not limited to:

Company formation and corporate advisory services
Immigration and visa advisory services
Real estate and investment advisory services
Tax and compliance advisory services
Any other regulated services provided by the firm

3. Legal and Regulatory Framework

KILC's AML obligations are governed by the following key legislation and regulations:

Proceeds of Crime Act 2002 (POCA): Criminalises money laundering and creates obligations to report suspected money laundering. Key offences include concealing criminal property (s.327), entering into arrangements concerning criminal property (s.328), and acquiring, using, or possessing criminal property (s.329). Failure to disclose (s.330) and tipping off (s.333A) are also criminal offences.
Terrorism Act 2000 (TACT): Creates offences relating to terrorist financing, including fundraising (s.15), use and possession (s.16), funding arrangements (s.17), and money laundering (s.18). Section 19 creates a duty to disclose where a person believes or suspects another has committed a terrorist financing offence.
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs 2017): Transposed the EU Fourth and Fifth Anti-Money Laundering Directives into UK law. Sets out requirements for customer due diligence, record-keeping, policies and procedures, staff training, and reporting.
Sanctions and Anti-Money Laundering Act 2018: Provides the UK's post-Brexit framework for financial sanctions and anti-money laundering regulations.
Bribery Act 2010: Criminalises bribery of UK and foreign public officials, as well as failure by commercial organisations to prevent bribery.

KILC also has regard to guidance issued by relevant supervisory bodies and HM Treasury's financial sanctions regime.

4. Key Roles and Responsibilities

The following key roles have been established to ensure effective AML compliance:

Money Laundering Reporting Officer (MLRO): Lisa Mao is the designated MLRO for KILC. The MLRO is responsible for receiving and assessing internal suspicious activity reports (SARs), making external disclosures to the National Crime Agency (NCA) where appropriate, overseeing the firm's AML compliance programme, and acting as the primary point of contact with regulatory authorities on AML matters.
Senior Management: The senior management of KILC is responsible for ensuring that adequate resources are allocated to AML compliance, approving and maintaining this policy, and fostering a culture of compliance throughout the firm.
All Staff: Every member of staff is responsible for understanding and complying with this policy, completing AML training as required, remaining vigilant for signs of money laundering and terrorist financing, and reporting any suspicions to the MLRO promptly.

5. Enterprise-Wide Risk Assessment (EWRA)

KILC conducts and maintains an enterprise-wide risk assessment that identifies and assesses the money laundering and terrorist financing risks to which the firm is exposed. The risk assessment takes into account:

Client risk factors: The nature of our client base, including clients from higher-risk jurisdictions, politically exposed persons (PEPs), and clients in high-risk sectors.
Service risk factors: The types of services we provide and their susceptibility to being used for money laundering purposes.
Geographic risk factors: The jurisdictions in which we operate and from which our clients originate, with particular attention to countries identified as higher risk by FATF or HM Treasury.
Transaction risk factors: The nature and complexity of transactions, including those involving unusual payment methods or structures.
Delivery channel risk factors: How our services are delivered, including non-face-to-face relationships.

The EWRA is reviewed at least annually and updated whenever there are material changes to the firm's risk profile. The findings of the EWRA inform our policies, procedures, controls, and the level of due diligence applied to individual client relationships.

6. Customer Due Diligence (CDD)

KILC applies customer due diligence measures in the following circumstances:

When establishing a business relationship with a new client.
When carrying out an occasional transaction.
When there is a suspicion of money laundering or terrorist financing.
When there are doubts about the veracity or adequacy of previously obtained identification documents or information.

Standard CDD measures include:

Identification: Obtaining the name, date of birth, residential address, and any other information required to identify the client. For corporate clients, this includes identifying the entity, its directors, and beneficial owners.
Verification: Verifying the client's identity on the basis of documents, data, or information obtained from a reliable and independent source. Acceptable documents include valid passports, driving licences, and national identity cards.
Beneficial ownership: Identifying and taking reasonable measures to verify the identity of any beneficial owner, being any individual who ultimately owns or controls more than 25% of the shares, voting rights, or who otherwise exercises control over the management of the entity.
Purpose and nature: Obtaining information on the purpose and intended nature of the business relationship or transaction.

KILC will not establish or continue a business relationship, or carry out a transaction, where satisfactory CDD cannot be completed. Where CDD cannot be completed for an existing client, the relationship will be terminated and consideration given to whether a SAR is required.

7. Enhanced Due Diligence (EDD)

Enhanced due diligence is applied in higher-risk situations, including but not limited to:

Business relationships or transactions with persons established in high-risk third countries identified by HM Treasury or FATF.
Clients identified as politically exposed persons (PEPs), their family members, or known close associates.
Complex or unusually large transactions, or unusual patterns of transactions, which have no apparent economic or lawful purpose.
Non-face-to-face business relationships or transactions where additional identity verification risks exist.
Any other situation where the firm's risk assessment indicates a higher risk of money laundering or terrorist financing.

EDD measures may include obtaining additional identification and verification documents, conducting enhanced background checks, establishing the source of funds and source of wealth, obtaining senior management approval for establishing or continuing the business relationship, and conducting more frequent and intensive ongoing monitoring.

8. Politically Exposed Persons (PEPs)

KILC screens all clients and beneficial owners to determine whether they are a PEP, a family member of a PEP, or a known close associate of a PEP. A PEP is defined as an individual who is, or has been, entrusted with a prominent public function, including:

Heads of state, heads of government, ministers, and deputy or assistant ministers
Members of parliament or similar legislative bodies
Members of the governing bodies of political parties
Members of supreme courts, constitutional courts, or other high-level judicial bodies
Members of courts of auditors or the boards of central banks
Ambassadors, charges d'affaires, and high-ranking officers in the armed forces
Members of the administrative, management, or supervisory bodies of state-owned enterprises
Directors, deputy directors, and members of the board of an international organisation

Where a PEP relationship is identified, EDD measures are applied, and senior management approval is obtained before establishing or continuing the business relationship.

9. Sanctions Screening

KILC screens all clients, beneficial owners, and relevant connected parties against applicable sanctions lists, including:

HM Treasury's consolidated list of financial sanctions targets
The Office of Financial Sanctions Implementation (OFSI) list
UN Security Council sanctions lists
EU sanctions lists (where applicable)

Screening is performed at the onboarding stage and on an ongoing basis throughout the client relationship. Any potential sanctions matches are escalated immediately to the MLRO for assessment. KILC will not provide services to any individual or entity that is subject to financial sanctions.

10. Ongoing Monitoring

KILC conducts ongoing monitoring of its business relationships to ensure that:

Transactions being conducted are consistent with our knowledge of the client, their business, and risk profile.
Client information and CDD records are kept up to date, particularly for higher-risk clients.
Any changes in the client's risk profile are identified and addressed promptly.
Unusual or suspicious activity is detected and reported to the MLRO.

The level and frequency of monitoring is risk-based, with higher-risk relationships subject to more frequent and intensive scrutiny. CDD records are reviewed and updated at least annually for high-risk clients, every three years for medium-risk clients, and every five years for lower-risk clients.

11. Suspicious Activity Reporting (SAR)

All staff have a legal obligation to report any knowledge or suspicion of money laundering or terrorist financing. The process is as follows:

Internal reporting: Any member of staff who has knowledge, suspicion, or reasonable grounds for suspicion of money laundering or terrorist financing must report their concerns to the MLRO immediately using the firm's internal SAR form.
MLRO assessment: The MLRO will assess the internal report and determine whether there are reasonable grounds to suspect money laundering or terrorist financing.
External reporting: Where the MLRO determines that a disclosure is required, they will submit a SAR to the National Crime Agency (NCA) via the NCA's SAR Online system.
Consent requests: Where a transaction is suspected of involving criminal property and the firm needs to proceed with the transaction, the MLRO will seek appropriate consent from the NCA before proceeding.

Staff must not inform the client or any third party that a SAR has been made or is being considered ("tipping off"), as this is a criminal offence under POCA and TACT. Records of all internal and external SARs are maintained securely by the MLRO.

12. Training

KILC ensures that all relevant staff receive appropriate AML training, including:

Induction training: All new staff receive AML training as part of their induction, covering the firm's AML policies and procedures, how to identify suspicious activity, and how to make internal reports.
Ongoing training: Regular refresher training is provided at least annually, and additional training is delivered when there are significant changes in legislation, regulations, or the firm's risk profile.
Role-specific training: Specialist training is provided for staff in higher-risk roles, including those responsible for client onboarding and those handling complex or cross-border transactions.

Records of all training provided are maintained, including dates, content covered, and attendees.

13. Independent Assurance and Audit

KILC's AML compliance framework is subject to independent assurance and audit to ensure its effectiveness. This includes:

Regular internal reviews of AML policies, procedures, and controls.
Testing of CDD files and processes to ensure compliance with requirements.
Review of SAR reporting processes and record-keeping.
Assessment of training effectiveness and staff awareness.

Findings from independent assurance activities are reported to senior management and used to inform improvements to the firm's AML framework.

14. Third Parties and Reliance

Where KILC relies on a third party to apply CDD measures, the firm retains ultimate responsibility for ensuring that adequate CDD has been performed. Reliance on third parties is only permitted where:

The third party is subject to AML requirements consistent with those of the UK.
The third party consents to make CDD information available upon request.
KILC is satisfied that the third party applies CDD measures and record-keeping requirements that are consistent with those set out in the MLRs 2017.

KILC maintains a register of third parties upon which it relies for CDD purposes and periodically reviews the adequacy of their AML controls.

15. Governance and Record-Keeping

KILC maintains comprehensive records of all AML activities, including:

CDD and identification documents obtained for all clients and beneficial owners.
Records of all transactions carried out in the course of a business relationship or occasional transaction.
All internal and external suspicious activity reports.
Risk assessments, both at the enterprise level and for individual client relationships.
Training records.
Results of internal audits and independent assurance activities.

CDD records and transaction records are retained for a minimum of five years after the end of the business relationship or the date of the occasional transaction, as required by the MLRs 2017. Records may be retained for longer where required by law or where the firm considers it appropriate for legal or regulatory purposes.

16. Prohibited Activities

The following activities are strictly prohibited:

Knowingly assisting, facilitating, or participating in money laundering or terrorist financing.
Tipping off a client or any third party about a SAR or investigation.
Failing to report knowledge or suspicion of money laundering or terrorist financing to the MLRO.
Prejudicing an investigation by disclosing information or interfering with evidence.
Accepting cash payments in excess of any applicable thresholds.
Circumventing or attempting to circumvent any AML controls or procedures.

Any breach of this policy will be treated as a serious disciplinary matter and may result in dismissal and/or criminal prosecution.

17. AML Compliance Checklist

The following checklist should be followed for every new client engagement:

Client identification and verification completed
Beneficial owner identification and verification completed (for corporate clients)
Sanctions screening completed with no matches
PEP screening completed
Source of funds established (where required)
Risk assessment completed and risk rating assigned
EDD applied where higher-risk factors identified
Senior management approval obtained (where required)
Purpose and nature of the business relationship documented
All CDD records filed and securely stored

18. Definitions

Money Laundering: The process by which the proceeds of crime are converted into assets which appear to have a legitimate origin, so that they can be retained permanently or recycled to fund further crime. Under POCA, money laundering includes concealing, disguising, converting, transferring, or removing criminal property from the UK, as well as entering into or becoming concerned in arrangements which facilitate the acquisition, retention, use, or control of criminal property.
Terrorist Financing: The provision or collection of funds with the intention or knowledge that they are to be used to carry out acts of terrorism, or the making available of funds or financial services to terrorist organisations or individuals.
Suspicious Activity Report (SAR): A report made to the NCA where there is knowledge, suspicion, or reasonable grounds for suspicion that a person is engaged in money laundering or terrorist financing.
Customer Due Diligence (CDD): The process of identifying and verifying the identity of clients and beneficial owners, understanding the nature and purpose of the business relationship, and conducting ongoing monitoring.
Enhanced Due Diligence (EDD): Additional CDD measures applied in higher-risk situations to manage and mitigate those risks effectively.
Politically Exposed Person (PEP): An individual who is, or has been, entrusted with a prominent public function.
Beneficial Owner: Any individual who ultimately owns or controls the client, or on whose behalf a transaction or activity is being conducted, including any person who exercises ultimate effective control over a legal entity.
MLRO: Money Laundering Reporting Officer — the individual designated to receive internal disclosures of suspicious activity and make external reports to the NCA.

19. Contact

For any questions regarding this policy, or to report suspicious activity, please contact:

MLRO: Lisa Mao
Email: compliance@kilc.co.uk
Post: Keane International Legal Consultancy LLP, 128 City Road, London EC1V 2NX

This policy is reviewed at least annually by the MLRO and senior management, and updated as necessary to reflect changes in legislation, regulation, or the firm's risk profile.