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Anti-Money Laundering
(AML) Policy
With Aston VIP
AML
Compliance Policy
01 January 2025
01 January 2025
Aston VIP Ltd
15581061
128 City Road, London, United Kingdom, EC1V 2NX
+44 20805 08064
contact@aston.ae
1. Introduction
At Aston VIP Ltd, we are committed to upholding the highest standards of compliance and integrity in our operations. Our Anti-Money Laundering (AML) Policy is a cornerstone of our efforts to combat financial crime, safeguard the integrity of financial transactions, and ensure adherence to global and local regulatory standards.
Money laundering undermines the stability of financial systems and poses significant risks to businesses, governments, and society as a whole. This policy reflects our unwavering commitment to detecting, preventing, and addressing money laundering activities within our operations and on behalf of our clients.
Aston VIP Ltd operates within a comprehensive compliance framework that integrates our AML policy with Know Your Customer (KYC) protocols, data protection measures, and other regulatory obligations. This approach not only ensures legal compliance but also reinforces trust and accountability in our client relationships. By implementing this policy, we aim to mitigate risks, support global efforts to combat illicit financial activities, and maintain our reputation as a trusted service provider.
This policy applies to all areas of our operations, including company formation, bank account setup, tax consultancy, and financial transactions. It outlines the responsibilities of our employees, clients, and third-party partners in preventing money laundering and other financial crimes.
2. Purpose of the policy
The primary objective of this AML Policy is to ensure that Aston VIP Ltd complies with all applicable laws and regulations aimed at preventing money laundering and related financial crimes. This policy provides a clear framework for identifying, assessing, and mitigating risks associated with illicit activities.
Our AML Policy serves the following key purposes
Regulatory compliance
To adhere to the UK Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, and international standards such as the Financial Action Task Force (FATF) Recommendations.
Risk mitigation
To identify, assess, and address risks related to money laundering, terrorism financing, and other illicit activities, thereby protecting our clients and stakeholders.
Client trust
To build confidence among clients, partners, and regulators by demonstrating our commitment to ethical practices and robust compliance measures.
Reputation management
To safeguard Aston VIP Ltd’s reputation by ensuring that our services are not misused for illegal purposes or activities.
Business integrity
To maintain the highest standards of professionalism and integrity in all client interactions and business relationships.
This policy serves as a reference for our employees, clients, and partners, ensuring a shared understanding of our responsibilities and obligations in combating financial crime. By embedding AML principles into our operations, Aston VIP Ltd reinforces its dedication to fostering a secure and compliant financial ecosystem.
3. Scope
This AML Policy applies to all aspects of Aston VIP Ltd’s operations, encompassing our services, employees, clients, and third-party partners. The policy is designed to ensure comprehensive compliance with AML regulations across all jurisdictions where we operate.
3.1 Applicability
Clients
This policy applies to all individuals, businesses, and organisations engaging with Aston VIP Ltd for services such as company formation, bank account assistance, and tax consultancy. Both new and existing clients are subject to AML procedures, including due diligence and transaction monitoring.
Employees
All employees, contractors, and consultants of Aston VIP Ltd involved in client onboarding, due diligence, or compliance activities are required to follow the procedures outlined in this policy. Employees play a crucial role in implementing AML measures and reporting suspicious activities.
Third-party partners
Service providers, intermediaries, and other external entities working with Aston VIP Ltd must adhere to our AML standards. Contracts with third parties include provisions requiring compliance with this policy and applicable regulations.
3.2 Jurisdictional Coverage
This policy is applicable across all jurisdictions where Aston VIP Ltd operates, including the United Arab Emirates, the United Kingdom, and other international markets. While the framework is primarily based on UK regulations, it aligns with global standards to ensure seamless compliance across borders.
By defining a broad scope, Aston VIP Ltd ensures that no aspect of its operations is left unaddressed, enabling a comprehensive and proactive approach to AML compliance.
4. Regulatory Framework
Aston VIP Ltd operates within a robust legal framework designed to combat money laundering and related financial crimes. This policy integrates local and international standards, ensuring compliance with complex regulatory requirements.
Key regulations and standards
UK Money Laundering Regulations 2017
This regulation forms the foundation of AML compliance in the UK. It mandates stringent requirements for client identification, risk assessment, and reporting of suspicious activities. Aston VIP Ltd strictly adheres to these provisions.
Proceeds of Crime Act 2002
This act establishes the legal basis for identifying and preventing the proceeds of criminal activities. Aston VIP Ltd’s policies and procedures are designed to detect and mitigate such risks.
Sanctions and Anti-Money Laundering Act 2018
This legislation empowers authorities to impose sanctions and enforce AML measures. Aston VIP Ltd conducts regular checks against international sanctions lists to ensure compliance.
Financial Action Task Force (FATF) Recommendations
As a global standard-setting body, the Financial Action Task Force (FATF) provides guidelines for combating money laundering and terrorism financing. Aston VIP Ltd incorporates these recommendations to align with international best practices.
UK General Data Protection Regulation (UK GDPR)
Aston VIP Ltd ensures that all personal data collected during AML procedures is handled in compliance with data protection laws, safeguarding client privacy and confidentiality.
5. Client Due Diligence (CDD)
Client Due Diligence (CDD) is the foundation of Aston VIP’s AML compliance strategy, ensuring that we have a comprehensive understanding of our clients and their activities. This process is mandatory for all new and existing clients and involves the verification of client identities, assessment of associated risks, and continuous monitoring to detect any unusual or suspicious activities.
The CDD process begins with the collection of primary identification documents, including government-issued IDs, passports, or corporate registration certificates. These documents are verified through reliable sources to ensure their authenticity. In addition, clients are required to provide proof of address, such as utility bills or lease agreements, which must be dated within a specified timeframe to confirm their current residency.
Aston VIP also mandates the disclosure of the source of funds and the intended purpose of transactions. Clients must provide supporting documentation, such as bank statements, employment records, or contracts, to substantiate the legitimacy of their financial activities.
This is crucial to ensuring that our services are not used to facilitate illegal activities.
The business purpose of the client’s engagement with Aston VIP is also carefully evaluated. We assess whether the nature of the client’s operations aligns with their declared intentions and whether any red flags arise during this assessment. This detailed review allows us to categorise clients based on their risk levels, with higher scrutiny applied to those deemed medium or high risk.
Throughout the client relationship, Aston VIP employs ongoing due diligence measures to ensure that the information provided at onboarding remains accurate and up to date. Changes in client profiles, such as a new source of funds, significant transactions, or changes in ownership structures, are reviewed and verified as part of our commitment to regulatory compliance.
Aston VIP also utilises advanced technology to streamline the CDD process. Automated systems cross-reference client information against global sanctions lists, politically exposed persons (PEP) databases, and adverse media reports. These tools enhance the accuracy and efficiency of our due diligence efforts while reducing manual errors.
Failure to comply with CDD requirements may result in service denial or immediate termination of services. Aston VIP reserves the right to report non-compliance or suspicious activities to the relevant authorities as mandated by law. By adhering to stringent CDD protocols, Aston VIP ensures that our operations remain transparent, ethical, and aligned with global AML standards.
6. Enhanced Due Diligence (EDD)
Enhanced Due Diligence (EDD) is an advanced layer of verification applied to high-risk clients, transactions, or jurisdictions. While CDD establishes the baseline for client verification, EDD addresses situations that require a deeper analysis to mitigate heightened risks. Aston VIP’s EDD measures are designed to ensure comprehensive compliance with AML regulations and to safeguard our operations against financial crimes.
EDD is typically initiated in cases involving politically exposed persons (PEPs), clients operating in high-risk jurisdictions, or transactions involving complex financial structures. The process includes a detailed analysis of the client’s financial history, background checks, and the collection of additional documentation to verify the legitimacy of their activities. Clients subject to EDD may be required to provide audited financial statements, detailed business plans, or declarations regarding the nature and purpose of their transactions.
In addition to document verification, Aston VIP conducts in-depth risk assessments to identify potential red flags. This involves analysing transaction patterns, source and destination of funds, and the client’s overall risk profile. Any anomalies detected during this process are flagged for further review by our compliance team.
Ongoing monitoring is a critical component of EDD. High-risk clients are subject to regular reviews to ensure that their activities remain consistent with their declared business objectives. Transactions exceeding certain thresholds are scrutinised, and any deviations from established patterns are investigated promptly.
Aston VIP also employs specialised tools and third-party services to enhance the accuracy of EDD procedures. These include access to global databases of sanctions, PEPs, and adverse media reports. By leveraging these resources, we ensure that our assessments are thorough and aligned with international best practices.
Failure to meet EDD requirements may result in the suspension or termination of services. Aston VIP takes a zero-tolerance approach to non-compliance, reporting any suspicious activities to the relevant regulatory authorities without delay. By implementing robust EDD measures, Aston VIP reinforces its commitment to maintaining the integrity of financial systems and upholding its reputation as a trusted service provider.
Failure to comply with CDD requirements may result in service denial or immediate termination of services. Aston VIP reserves the right to report non-compliance or suspicious activities to the relevant authorities as mandated by law. By adhering to stringent CDD protocols, Aston VIP ensures that our operations remain transparent, ethical, and aligned with global AML standards.
7. Monitoring and reporting
Monitoring and reporting form the backbone of Aston VIP’s efforts to detect and prevent money laundering. Through continuous oversight of client activities and transactions, we ensure compliance with AML regulations while identifying potential risks. This proactive approach allows Aston VIP to act swiftly in addressing irregularities and safeguarding the integrity of its operations.
Monitoring involves the real-time analysis of transactions to identify patterns, inconsistencies, and deviations from expected behaviour. Aston VIP employs advanced analytics tools and artificial intelligence to enhance the accuracy and efficiency of this process. These tools enable the detection of anomalies that may indicate suspicious activities, such as sudden large transfers, transactions involving high-risk jurisdictions,
or unusual account behaviour.
Our compliance team conducts periodic reviews of client accounts to ensure that their activities align with their declared business purposes. These reviews include the evaluation of financial statements, transaction histories, and any updates to the client’s risk profile. Clients with high-risk ratings are subject to more frequent and rigorous monitoring to mitigate potential threats.
When suspicious activities are identified, Aston VIP files Suspicious Activity Reports (SARs) with the appropriate regulatory authorities. These reports include detailed information about the client, the nature of the suspicious activity, and any supporting evidence. SARs are submitted in accordance with statutory timelines, ensuring compliance with legal obligations.
Aston VIP also maintains meticulous records of all client interactions, transactions, and due diligence efforts. These records are stored securely and retained for a minimum of five (5) years, as required by AML regulations. The availability of comprehensive documentation ensures accountability and facilitates audits or investigations by regulatory bodies.
In addition to internal monitoring, Aston VIP collaborates with external partners and regulatory authorities to stay updated on emerging AML risks and trends. This includes participating in industry forums, attending training sessions, and implementing recommendations from global AML organisations.
By integrating robust monitoring and reporting mechanisms into its operations, Aston VIP ensures that its services remain compliant with regulatory standards while actively contributing to the prevention of financial crimes.
8. Employee training and awareness
Employee training and awareness are essential components of Aston VIP’s AML framework. Our training programmes are designed to equip employees with the knowledge and skills needed to identify, prevent, and report money laundering activities effectively. By fostering a culture of compliance, Aston VIP ensures that its workforce remains vigilant and proactive in addressing AML challenges.
All employees, including new hires and contractors, undergo comprehensive AML training as part of their onboarding process. This training covers the fundamentals of money laundering, the importance of AML regulations, and Aston VIP’s internal policies and procedures. Employees are taught how to recognise red flags, such as unusual client behaviour, complex financial transactions, or attempts to bypass due diligence requirements.
Regular refresher courses are conducted to ensure that employees stay updated on the latest AML trends, regulatory changes, and best practices. These courses include scenario-based exercises, case studies, and interactive workshops to enhance practical understanding. Employees are also tested on their knowledge of AML policies to reinforce their learning and identify areas for improvement.
Aston VIP’s training programmes are tailored to the specific roles and responsibilities
of employees. For example, compliance officers receive advanced training on risk assessment, transaction monitoring, and regulatory reporting, while client-facing staff
are trained to conduct due diligence and verify documentation.
In addition to formal training, Aston VIP promotes ongoing awareness through internal communications, newsletters,
and access to AML resources. Employees are encouraged to report any suspicious activities or compliance concerns through a confidential reporting channel, ensuring
that potential issues are addressed promptly.
By investing in employee training and awareness, Aston VIP not only enhances its AML capabilities but also demonstrates its commitment to fostering a knowledgeable and accountable workforce. This approach ensures that Aston VIP remains a leader in AML compliance and a trusted partner for its clients.
9. Client responsibilities
Clients play a crucial role in ensuring compliance with AML regulations. Aston VIP requires all clients to adhere to the responsibilities outlined in this policy to maintain a transparent and secure financial ecosystem. Failure to meet these responsibilities may result in
service termination or legal consequences.
Clients are required to provide accurate and complete information during the onboarding process. This includes submitting valid identification documents, proof of address, and any additional documentation requested by Aston VIP. Clients must also disclose the legitimate source of funds and the intended purpose of their transactions, ensuring that all financial activities are above board.
Throughout the client relationship, clients are expected to notify Aston VIP of any changes to their personal or business information. This includes updates to ownership structures, financial activities, or contact details. Failure to provide timely updates may hinder Aston VIP’s ability to fulfil its AML obligations and could result in service disruptions.
Clients must also cooperate with Aston VIP during periodic reviews and audits. This includes responding promptly to requests for information, providing access to relevant documents, and addressing any discrepancies identified during the review process.
Aston VIP reserves the right to suspend services if clients fail to meet these requirements.
In addition to these responsibilities, clients are prohibited from engaging in activities that contravene AML regulations. This includes attempting to use Aston VIP’s services to launder money, finance terrorism, or facilitate other illegal activities. Clients found to be
in violation of these rules will be reported to the relevant authorities and may face legal action.
By adhering to these responsibilities, clients contribute to the integrity of Aston VIP’s operations and support global efforts to combat financial crime. Aston VIP provides clear guidance and support to help clients understand their obligations and maintain compliance with AML regulations.
10. Limitations of liability
Aston VIP is committed to fulfilling its AML obligations with diligence and professionalism. However, clients must acknowledge that Aston VIP’s role is limited to the services outlined in its agreements. Aston VIP is not liable for losses or damages resulting from circumstances beyond its control, including actions taken in compliance with AML regulations.
Aston VIP’s liability does not extend to penalties, fines, or legal actions imposed on clients due to their failure to meet AML requirements. Clients are solely responsible for providing accurate information, complying with regulatory obligations, and addressing any issues that arise from their activities.
In cases where services are suspended or terminated due to non-compliance, Aston VIP is not liable for any resulting disruptions or financial losses. Similarly, Aston VIP is not responsible for delays or complications caused by third-party service providers, such as banks or regulatory authorities.
To ensure transparency, Aston VIP maintains clear communication with clients regarding their responsibilities and the potential consequences of non-compliance. By understanding these limitations, clients can better appreciate the shared responsibility
of maintaining compliance and mitigating risks.
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For any inquiries, clarifications, or assistance, please contact Aston VIP via email or by phone. Our team is available to provide support and address your concerns promptly.
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