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AML Policy

Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy

M'Cube Global Ltd
Regus House, Admirals Park, Victory Way, Dartford, DA2 6QD, United Kingdom

Compliance contact: compliance@mcubepay.com · +44 20 3818 1029 · www.mcubepay.com

Contents

Introduction and Purpose

M'Cube Global Limited operates as an agent of a Small Payment Institution in accordance with the Payment Services Regulations 2017 and provides remittance and payment services under the regulatory permissions of its principal.

M'Cube Global Limited recognises its critical role in combating money laundering and terrorist financing and is subject to the comprehensive Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) legislative framework in the UK applicable to payment and remittance services.

This policy outlines M'Cube Global's unwavering commitment to preventing its services from being used for money laundering, terrorist financing, or any other financial crime. It establishes the framework for a robust AML/CTF compliance programme, designed to detect, prevent, and report suspicious activities.

The purpose of this policy is to:

  • Articulate M'Cube Global's zero-tolerance approach to money laundering and terrorist financing.
  • Ensure full compliance with all relevant UK AML/CTF laws, regulations, and guidance.
  • Define clear responsibilities and procedures for identifying, assessing, managing, and mitigating financial crime risks.
  • Protect M'Cube Global from legal and regulatory penalties, financial losses, and reputational damage.
  • Foster a strong anti-financial crime culture amongst all personnel.

Scope

This policy applies to all business activities conducted by M'Cube Global. It applies to all directors, employees (permanent, fixed-term, temporary), contractors, agents, and any other third parties ("Personnel") working for or on behalf of M'Cube Global, regardless of their location or role.

Definitions

Money Laundering (ML): The process by which criminals disguise the illegal origins of criminal proceeds and integrate them into the legitimate financial system. It typically involves three stages: Placement, Layering, and Integration.

Terrorist Financing (TF): The provision or collection of funds, by any means, directly or indirectly, with the intention that they should be used or in the knowledge that they are to be used, in full or in part, to carry out terrorist acts.

Financial Crime: A broad term encompassing money laundering, terrorist financing, bribery, corruption, fraud, tax evasion, and sanctions breaches.

Money Laundering Regulations 2017 (MLR 2017): The UK statutory instrument that implements the Fourth (and partially Fifth) EU Anti-Money Laundering Directive into UK law.

Proceeds of Crime Act 2002 (POCA): The primary UK legislation that covers money laundering offences.

Terrorism Act 2000 (TACT): UK legislation dealing with terrorism offences, including terrorist financing.

Money Laundering Reporting Officer (MLRO): The senior individual within M'Cube Global designated with overall responsibility for AML/CTF compliance and for receiving and making Suspicious Activity Reports (SARs) to the National Crime Agency (NCA).

Deputy MLRO: An individual formally appointed to assist the MLRO and act in their absence.

Customer Due Diligence (CDD): The process of identifying the customer and verifying their identity, identifying any beneficial owners, understanding the purpose and intended nature of the business relationship, and conducting ongoing monitoring.

Know Your Customer (KYC): The process of identifying and verifying the identity of individual customers.

Know Your Business (KYB): The process of identifying and verifying the identity of corporate or other non-individual customers.

Beneficial Owner (BO): The natural person(s) who ultimately owns or controls a customer, or on whose behalf a transaction or activity is being conducted.

Politically Exposed Person (PEP): An individual who holds a prominent public function, or a family member or known associate of such an individual, presenting a higher risk of bribery or corruption.

Sanctions Screening: The process of checking customers and transactions against official financial sanctions lists.

Suspicious Activity Report (SAR): A report made to the National Crime Agency (NCA) when there are reasonable grounds to suspect money laundering or terrorist financing.

Tipping Off: The act of informing a customer or a third party that a SAR has been made, or that a money laundering investigation is being conducted, which is a criminal offence.

Key Elements of the AML/CTF Programme

1. Risk Assessment

  • M'Cube Global will undertake a comprehensive, documented, and regularly updated money laundering and terrorist financing risk assessment that covers its customers, products, services, transactions, delivery channels, and geographic areas of operation annually and report results to the Board to inform risk appetite and resource allocation.
  • This assessment will inform the design and implementation of M'Cube Global's controls and procedures, adopting a risk-based approach.

2. Internal Controls and Procedures

Robust internal controls and procedures will be maintained to mitigate identified risks, including:

  • Customer Due Diligence (CDD) Procedures:
    • Customer Acceptance: Clear criteria for accepting or rejecting new customers.
    • Identity Verification (KYC/KYB): Procedures for verifying the identity of all customers (individuals and entities) and their beneficial owners using reliable, independent sources.
    • Purpose of Relationship: Understanding the purpose and intended nature of the business relationship.
    • Enhanced Due Diligence (EDD): Application of stricter and more intensive measures for higher-risk customers (e.g., PEPs, high-risk geographies, complex structures) or unusual transactions. This includes verifying source of funds and source of wealth where appropriate.
    • Simplified Due Diligence (SDD): Applied only in specific, low-risk circumstances permitted by regulations, with clear justification.
  • Ongoing Monitoring:
    • Transaction Monitoring: Continuous monitoring of customer transactions for unusual patterns, deviations from expected behaviour, or indicators of suspicious activity.
    • Relationship Review: Periodic review of customer risk profiles and CDD documentation to ensure they remain current and accurate.
    • Trigger Events: Reviews triggered by significant changes to customer information or risk profile (e.g., change of beneficial owner, adverse media, significant increase in activity).
  • Sanctions Screening:
    • All customers, beneficial owners, and relevant parties to transactions will be screened against official sanctions lists (e.g., HM Treasury's Office of Financial Sanctions Implementation - OFSI, UN, EU, US OFAC) prior to onboarding and on an ongoing basis.
    • Any positive match will trigger immediate internal reporting to the MLRO and, if confirmed, action to freeze funds or transactions and notify OFSI, without tipping off the customer.
  • Record Keeping:
    • All records of CDD, transaction data, and internal and external reports will be maintained securely for a minimum of five years from the end of the business relationship or the date of the last transaction.

3. Money Laundering Reporting Officer (MLRO) and Management

  • Appointment: M'Cube Global has appointed a suitably senior and experienced individual as the MLRO, who has direct access to the Board of Directors. A Deputy MLRO may also be appointed.
  • Responsibilities: The MLRO is responsible for:
    • Overseeing M'Cube Global's AML/CTF compliance programme.
    • Receiving and assessing all internal suspicious activity reports from personnel.
    • Determining whether reasonable grounds for suspicion exist and submitting SARs to the NCA.
    • Acting as the primary point of contact for external authorities (NCA, FCA, OFSI).
    • Providing guidance and training to personnel on AML/CTF matters.
    • Preparing regular AML/CTF management information for senior management and the Board.

4. Training and Awareness

  • Mandatory Training: All relevant personnel (especially those in customer-facing roles, operations, compliance, and management) will receive mandatory, comprehensive, and role-specific AML/CTF training upon joining and at least annually thereafter.
  • Content: Training will cover:
    • The nature and risks of money laundering and terrorist financing.
    • M'Cube Global's specific AML/CTF policies and procedures.
    • How to identify and report suspicious activity.
    • The legal obligations and consequences of non-compliance, including tipping off.
  • Records: Records of all AML/CTF training completed by personnel will be maintained.

5. Internal Audit and Review

  • M'Cube Global's internal audit function (or an independent external reviewer) will periodically review the effectiveness of the AML/CTF controls, policies, and procedures.
  • Findings from internal and external reviews will be addressed promptly and remedial actions implemented.

Suspicious Activity Reporting (SAR) Procedures

1. Internal Reporting

  • All personnel who have reasonable grounds to suspect money laundering or terrorist financing must report their suspicions immediately to the MLRO (or Deputy MLRO) using the prescribed internal reporting form/procedure.
  • Concerns must be reported regardless of the value of the transaction or the outcome of CDD.
  • Personnel must not discuss their suspicions with the customer or any third party involved in the transaction.

2. MLRO Assessment

  • Upon receiving an internal report, the MLRO will promptly assess the information, conduct further internal enquiries if necessary, and determine whether there are reasonable grounds to suspect money laundering or terrorist financing.
  • The MLRO has the authority to request additional information from any department.

3. External Reporting

  • If the MLRO determines there are reasonable grounds for suspicion, a SAR will be submitted to the National Crime Agency (NCA) as soon as practicable.
  • Consent from the NCA will be sought before proceeding with a suspicious transaction if continuing the transaction would constitute a money laundering offence (i.e., where there is knowledge or suspicion of criminal property).

4. No Tipping Off

  • It is a criminal offence to "tip off" a person that a SAR has been made, or that an investigation into money laundering is underway. All personnel must strictly adhere to this prohibition.

Governance and Responsibilities

Board of Directors

  • Ultimate responsibility for M'Cube Global's AML/CTF compliance.
  • Approves the AML Policy and oversees its implementation.
  • Ensures the MLRO has sufficient seniority, independence, and resources.

Money Laundering Reporting Officer (MLRO)

  • The cornerstone of the AML/CTF framework.
  • Responsible for day-to-day oversight of AML/CTF compliance.
  • Key decision-maker for internal and external suspicious activity reports.

Senior Management

  • Responsible for supporting the MLRO and fostering an AML/CTF compliant culture within their respective departments.
  • Ensures that departmental procedures align with this policy.

Compliance Officer

  • Assists the MLRO in monitoring compliance with AML/CTF regulations.
  • Provides regulatory interpretation and guidance.

All Personnel

  • Are personally responsible for understanding and adhering to this policy and all related AML/CTF procedures.
  • Must complete all mandatory AML/CTF training.
  • Have a legal obligation to report any suspicious activity to the MLRO.

Policy Review

This Anti-Money Laundering and Counter-Terrorist Financing (AML/CTF) Policy will be reviewed at least annually by the Board of Directors, or more frequently if there are significant changes in M'Cube Global's business model, customer risk profile, products, services, regulatory requirements (including FCA guidance), or emerging money laundering and terrorist financing typologies. Any amendments will be approved by the Board of Directors.