Skip to content 
Know Your Customer (KYC) Policy
With Aston VIP
KYC
Compliance Framework
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 recognise the importance of adhering to robust compliance standards, particularly in today’s global financial environment where risks of money laundering, terrorism financing, and other illicit activities are prevalent. Our Know Your Customer (KYC) policy is integral to maintaining the integrity of our services, ensuring that we operate within the legal framework established by both the United Kingdom and international regulatory bodies.
KYC is not merely a procedural requirement but a fundamental responsibility. It allows us to protect our clients, stakeholders, and the broader financial ecosystem by verifying identities, assessing risks, and implementing safeguards to prevent financial crime. This policy outlines the steps and measures we take to ensure compliance with relevant regulations, as well as the responsibilities of our employees, clients, and partners in upholding these standards.
The policy serves as a cornerstone of our broader compliance framework, working in tandem with our Anti-Money Laundering (AML) protocols and data protection measures. It applies to all aspects of our services, from company formation and bank account setup to tax consultancy and financial transactions. By ensuring rigorous compliance, Aston VIP Ltd reinforces its commitment to transparency, accountability, and ethical practices in all client engagements.
2. Purpose of the policy
The primary purpose of this KYC Policy is to ensure that Aston VIP Ltd complies with applicable laws and regulations, particularly those designed to combat financial crime. It provides a clear framework for identifying and verifying clients, monitoring their transactions, and mitigating risks associated with illegal activities.
This policy is designed to achieve several key objectives
Regulatory compliance
To meet the requirements of the UK Money Laundering Regulations 2017, FATF Recommendations, and other global standards.
Risk mitigation
To identify and address risks related to money laundering, terrorism financing, fraud, and other illicit activities.
Client trust
To build and maintain trust with our clients by demonstrating our commitment to transparency and due diligence.
Reputation management
To safeguard Aston VIP Ltd’s reputation by ensuring that our services are not misused for illegal purposes.
Business integrity
To ensure that all business relationships are conducted ethically and in compliance with the law.
This policy also provides a reference point for our employees and partners, outlining their responsibilities in implementing KYC measures effectively. By doing so, Aston VIP Ltd not only meets its legal obligations but also sets a benchmark for excellence in compliance practices.
3. Scope
The scope of this policy extends to all individuals and entities that engage with Aston VIP Ltd, as well as to our internal teams and third-party partners. Specifically, it applies to:
Clients
Any individual, corporate entity, or organisation that utilises Aston VIP Ltd’s services, including company formation, bank account assistance, and tax consultancy. This includes both new and existing clients, as well as occasional customers who engage us for specific transactions.
Employees
All staff members of Aston VIP Ltd, including permanent employees, contractors, and consultants, who are involved in client onboarding, due diligence, or compliance-related tasks. Employees are required to follow the procedures outlined in this policy to ensure consistency and accuracy in KYC implementation.
Third-party partners
Service providers, intermediaries, and other external entities that work with Aston VIP Ltd to deliver client services. These partners must also adhere to our KYC standards and demonstrate a commitment to compliance.
The policy is applicable across all jurisdictions where Aston VIP Ltd operates, taking into account local regulatory requirements. While the primary framework is based on UK regulations, such as the Proceeds of Crime Act 2002 and the Sanctions and Anti-Money Laundering Act 2018, it also aligns with international standards to ensure seamless compliance across borders.
By defining a broad scope, this policy ensures that no aspect of our operations is left unaddressed, enabling Aston VIP Ltd to maintain a comprehensive approach to compliance.
4. Regulatory Framework
Aston VIP Ltd operates within a highly regulated environment, where compliance with legal and regulatory requirements is paramount. This policy is grounded in a robust legal framework, incorporating both UK and international standards to address the complexities of global financial operations.
Key regulations and standards
UK Money Laundering Regulations 2017
This regulation forms the backbone of AML and KYC 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 to ensure compliance with national laws.
Proceeds of Crime Act 2002
This act criminalises money laundering and establishes the legal basis for confiscating proceeds from criminal activities. Our KYC measures are designed to detect and prevent such activities from occurring through our services.
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, FATF provides guidelines for combating money laundering and terrorism financing. Our policy incorporates these recommendations to align with international best practices.
UK General Data Protection Regulation (UK GDPR)
While implementing KYC measures, we ensure that personal data is handled in compliance with data protection laws, safeguarding client privacy.
This regulatory framework provides a solid foundation for our KYC policy, ensuring that Aston VIP Ltd meets its legal obligations while maintaining the highest standards of ethical conduct.
5. Key definitions
Understanding key terms is essential for implementing the KYC Policy effectively. Below are the definitions of critical concepts that guide our approach:
KYC (Know Your Customer)
A process of identifying and verifying the identity of clients to ensure their legitimacy and to assess potential risks related to money laundering or financial crimes.
AML (Anti-Money Laundering)
A set of procedures, laws, and regulations designed to detect, prevent, and report money laundering activities.
CDD (Client Due Diligence)
The standard process of collecting and verifying client information to evaluate potential risks.
EDD (Enhanced Due Diligence)
Additional checks conducted on high-risk clients or transactions to gain a deeper understanding of their activities and sources of funds.
PEP (Politically Exposed Person)
An individual who holds a prominent public position or is closely associated with such a person, making them more susceptible to bribery and corruption risks.
Sanctioned Entity
An individual, organisation, or country subject to economic or financial restrictions imposed by international bodies, such as the United Nations or the European Union.
Source of Funds
Documentation or information that demonstrates the origin of the financial resources being used in a transaction.
Beneficial Owner
The individual who ultimately owns or controls a legal entity or asset, even if it is held in another name.
These definitions provide clarity and consistency in the implementation of KYC measures, ensuring a shared understanding among all stakeholders.
6. Client Due Diligence (CDD)
Client Due Diligence (CDD) is the cornerstone of our KYC Policy. It involves identifying and verifying the identity of clients to ensure that they are legitimate and to assess any associated risks.
6.1 Steps in the CDD Process
1. Client identification
- Obtain personal information, such as full name, date of birth, and nationality.
- For businesses, collect company name, registration details, and ownership structure.
2. Verification
- Verify the authenticity of identification documents provided by the client.
- Use third-party databases and tools to confirm details against international sanctions lists, PEP lists, and adverse media reports.
3. Risk assessment
- Assign a risk profile to each client based on factors such as geographical location, type of business, and transaction patterns.
- High-risk clients are subject to additional scrutiny through Enhanced Due Diligence (EDD).
6.2 Required documentation
For individuals
A valid passport or national ID, proof of address (utility bill or bank statement), and evidence of source of funds.
For businesses
Incorporation certificates, Memorandum and Articles of Association, shareholder registry, and proof of business address.
CDD ensures that Aston VIP Ltd engages only with legitimate clients while maintaining compliance with regulatory requirements.
7. Enhanced Due Diligence (EDD)
Enhanced Due Diligence (EDD) is applied to clients or transactions identified as high-risk. These additional checks provide a deeper understanding of the client’s background, activities, and financial dealings.
7.1 When EDD is required
- Clients from jurisdictions identified as high-risk by FATF or other regulatory bodies.
- Transactions involving large sums of money or complex ownership structures.
- Politically Exposed Persons (PEPs) or their associates.
- Situations where the source of funds is unclear or unverifiable.
7.2 EDD procedures
- Collect detailed information about the client’s business operations, including financial statements and contracts.
- Verify the source of funds and wealth through supporting documentation.
- Conduct additional background checks using specialised tools and databases.
- Monitor the client’s transactions more frequently to detect unusual patterns or behaviours.
EDD is a critical component of our risk-based approach, ensuring that potential risks are thoroughly investigated and mitigated.
8. Ongoing monitoring
At Aston VIP Ltd, ongoing monitoring is a critical aspect of our KYC procedures. It ensures that client activities remain consistent with their declared profiles and that any potential risks are identified and addressed in real-time. This process is not limited to the initial client onboarding phase but continues throughout the duration of the client relationship.
8.1 Transaction monitoring
Aston VIP Ltd uses advanced monitoring systems to analyse client transactions. This includes:
Pattern analysis
Comparing current transactions against historical data to identify deviations or unusual behaviour.
Threshold alerts
Setting thresholds for transaction values, volumes, or types, triggering alerts for any activities that exceed these limits.
Geographical analysis
Monitoring transactions involving high-risk jurisdictions or countries subject to international sanctions.
If a transaction raises concerns, it is flagged for further investigation. Our compliance team reviews flagged transactions to determine whether they align with the client’s risk profile or warrant additional scrutiny.
8.2 Periodic reviews
Regular reviews are conducted to update client risk profiles and ensure the accuracy of KYC information. This includes:
Annual reviews
Standard clients undergo a full review of their records at least once a year.
High-risk reviews
Clients classified as high-risk are reviewed more frequently, with quarterly updates to their risk profiles.
Event-driven reviews
Reviews triggered by significant changes, such as new ownership structures, large transactions, or negative media coverage.
8.3 Real-time monitoring tools
We leverage state-of-the-art technology to facilitate real-time monitoring. This includes integrating third-party software for sanctions screening, PEP checks, and adverse media searches. These tools enable us to identify and address risks proactively.
Ongoing monitoring is not just a compliance requirement but a proactive measure to protect our clients and stakeholders from financial crime. It ensures that Aston VIP Ltd maintains the highest standards of operational integrity.
9. Reporting obligations
Reporting obligations are a cornerstone of Aston VIP Ltd’s compliance framework. These obligations ensure that any suspicious activities are promptly escalated and reported to the relevant authorities, minimising risks to the financial system.
9.1 Suspicious Activity Reports (SARs)
A Suspicious Activity Report (SAR) is submitted to the UK Financial Intelligence Unit (UKFIU) when a transaction or activity raises concerns about potential money laundering, terrorism financing, or other illicit activities. Examples of scenarios requiring a SAR include:
Large cash transactions
Significant cash deposits or withdrawals that appear unusual for the client’s profile.
Threshold alerts
Discrepancies between the client’s submitted documents and their declared activities.
Refusal to provide information
Clients unwilling to comply with reasonable requests for KYC or transaction details.
Our compliance team ensures that SARs are detailed and include all relevant information to assist authorities in their investigations. Once a SAR is filed, we refrain from notifying the client, in compliance with tipping-off regulations.
9.2 Internal reporting and escalation
Employees are trained to identify and escalate suspicious activities internally. The process involves:
- Reporting the activity to the Compliance Officer.
- The Compliance Officer conducting a thorough review of the case.
- Determining whether external reporting (e.g., filing a SAR) is required.
This structured approach ensures that all suspicious activities are addressed promptly and appropriately.
9.3 Reporting timeframes
All suspicious activities must be reported internally within 24 hours of detection. External reporting, where required, is completed within the legal timeframes specified by relevant regulations.
Reporting obligations reinforce Aston VIP Ltd’s commitment to transparency and its role in safeguarding the financial ecosystem.
10. Record retention
The retention of KYC and AML records is essential for compliance, accountability, and operational efficiency. At Aston VIP Ltd, we maintain meticulous records to ensure that we can meet regulatory requirements and respond effectively to audits or inquiries.
10.1 Types of records retained
The following types of records are retained as part of our KYC and AML processes:
Identification documents
Copies of passports, national IDs, and proof of address.
Transaction records
Details of all transactions processed on behalf of the client, including dates, amounts, and counterparties.
Risk assessments
Documentation of client risk profiles, including any changes made during periodic reviews.
Communication records
Correspondence with clients related to KYC, AML, or compliance matters.
10.2 Retention period
Records are retained for a minimum of five years after the termination of the client relationship or the completion of the last transaction. This retention period aligns with legal requirements under the UK Money Laundering Regulations 2017.
10.3 Secure storage and access
Employees are trained to identify and escalate suspicious activities internally. The process involves:
Digital records
Stored in encrypted databases with multi-factor authentication for access.
Physical records
Kept in locked, fireproof storage units with restricted access.
Access controls
Only authorised personnel, such as compliance officers and auditors, can access these records.
By maintaining comprehensive and secure records, Aston VIP Ltd demonstrates its commitment to compliance and operational excellence.
11. Roles and responsibilities
Aston VIP Ltd’s compliance framework is supported by clearly defined roles and responsibilities, ensuring that all employees and stakeholders contribute to the effective implementation of the KYC Policy.
11.1 Compliance officer
The Compliance Officer plays a central role in overseeing all aspects of KYC and AML compliance. Key responsibilities include:
- Developing and updating KYC and AML policies.
- Conducting regular audits to ensure adherence to internal procedures.
- Reviewing and approving risk assessments for high-risk clients.
- Filing Suspicious Activity Reports (SARs) with the relevant authorities.
11.2 Employees
All employees involved in client onboarding, transaction monitoring, or compliance activities are required to:
Aston VIP data protection officer
- Conduct thorough due diligence during client onboarding.
- Escalate suspicious activities to the Compliance Officer promptly.
- Participate in regular training to stay updated on KYC and AML regulations.
11.3 Third-party partners
Service providers and intermediaries must adhere to Aston VIP Ltd’s KYC standards. Contracts with third parties include clauses requiring compliance with our policies and relevant regulations.
Clearly defining roles and responsibilities ensures accountability and fosters a culture of compliance across the organisation.
12. Training and awareness
At Aston VIP Ltd, we believe that effective training is critical to ensuring that employees and partners are equipped to implement KYC measures consistently and accurately.
12.1 Training programme
Our training programme includes:
Induction training
New employees receive comprehensive training on KYC and AML requirements during their onboarding process.
Ongoing education
Regular workshops and e-learning modules to update staff on changes in regulations and industry best practices.
Scenario-based learning
Real-life case studies and role-playing exercises to help employees identify and address potential risks.
12.2 Certification and assessment
Employees are required to complete annual assessments to demonstrate their understanding of KYC and AML principles. Certificates of completion are issued for compliance purposes.
12.3 Partner training
Third-party partners are provided with training materials to ensure alignment with Aston VIP Ltd’s compliance framework.
Continuous training ensures that Aston VIP Ltd remains at the forefront of compliance excellence.
13. Non-compliance consequences
Aston VIP Ltd takes compliance with KYC and AML regulations very seriously. Non-compliance, whether intentional or unintentional, can have severe legal, financial, and reputational consequences for both the company and the individuals involved. This section outlines the potential repercussions and the measures taken to address non-compliance.
13.1 Consequences for Aston VIP Ltd
Failure to adhere to KYC and AML regulations can expose Aston VIP Ltd to:
1. Legal penalties
- Fines and sanctions imposed by regulatory authorities.
- Legal action under the UK Money Laundering Regulations 2017 and other applicable laws.
2. Operational risks
- Restrictions on operations, such as limitations on providing services in certain jurisdictions.
- Suspension or revocation of licences to operate.
3. Reputational damage
- Loss of trust among clients, partners, and stakeholders.
- Negative media coverage affecting the company’s brand and market position.
13.2 Consequences for employees
Employees found to be in breach of KYC or AML procedures may face:
1. Disciplinary actions
- Formal warnings, retraining, or reassignment of duties.
- Termination of employment for serious or repeated violations.
2. Personal liability
- Legal penalties, including fines or imprisonment, if the non-compliance is proven to be deliberate or negligent.
13.3 Addressing non-compliance
Aston VIP Ltd has a zero-tolerance policy for non-compliance. Steps taken to address violations include:
1. Internal investigations
- Identifying the root cause of the issue and assessing its impact.
- Reviewing processes to determine whether lapses were systemic or individual.
2. Corrective actions
- Implementing additional training for employees.
- Enhancing monitoring systems or updating policies and procedures.
3. Regulatory reporting
- Notifying relevant authorities of significant breaches and cooperating fully with investigations.
By enforcing strict consequences for non-compliance, Aston VIP Ltd reinforces its commitment to upholding the highest standards of integrity and accountability.
14. Review and updates
The dynamic nature of KYC and AML regulations necessitates regular reviews and updates to Aston VIP Ltd’s policies and procedures. This ensures that the company remains compliant with evolving legal requirements and industry best practices.
14.1 Annual reviews
The KYC Policy is reviewed annually by the Compliance Officer in collaboration with senior management. The review process includes:
Regulatory updates
Identifying changes to laws and guidelines, such as updates to the UK Money Laundering Regulations or FATF Recommendations.
Internal assessments
Evaluating the effectiveness of current policies based on audit findings and employee feedback.
Industry trends
Monitoring emerging risks and technological advancements to enhance compliance measures.
14.2 Interim updates
In addition to annual reviews, the KYC Policy is updated as needed to address:
New risks
Responding to emerging threats, such as new types of fraud or changes in global risk profiles.
Operational changes
Adjustments to Aston VIP Ltd’s services, client base, or geographical focus.
Regulatory changes
Immediate updates to comply with new laws or directives from regulatory authorities.
14.3 Communication of changes
When the policy is updated, the following steps are taken:
Employee notification
All staff members are informed of the changes and provided with updated training materials.
Client communication
Existing clients are notified of any changes that may impact their relationship with Aston VIP Ltd.
Public disclosure
Updates are reflected in the publicly available version of the policy on Aston VIP Ltd’s websites, aston.ae and astonvip.com.
Regular reviews and updates ensure that Aston VIP Ltd remains proactive and adaptive in its approach to KYC and AML compliance, reinforcing trust and confidence among clients and stakeholders.
Contact us – we’re ready to assist you!
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.
Prefer messaging? Contact us through messengers or simply give us a call: Our working hours: Monday to Friday, 9 AM – 6 PM CET
Saved monthly
Stay updated with our latest articles
We stay up-to-date with the latest news regarding business and company formation in Dubai, UAE
Crypto & VARA
March 27, 2025
Company Formation
March 27, 2025
UAE
March 27, 2025
Crypto & VARA
March 27, 2025
Company Formation
March 27, 2025
UAE
March 27, 2025
Economic Growth
March 25, 2025
UAE
March 25, 2025
Economic Growth
March 23, 2025
