AML & Financial Crime Policy

1. Purpose

Advanced Asset Management Ltd, trading as Crest Pay (“Crest Pay”, “we”, “our”, “us”) is committed to preventing the use of its services for money laundering, terrorist financing, fraud, bribery, tax evasion and other forms of financial crime.

This Policy establishes the standards and procedures that Crest Pay applies to identify, assess, monitor and mitigate financial crime risks in accordance with applicable UK legislation and recognised industry best practice.

2. Scope

This Policy applies to:

• Directors
• Employees
• Consultants
• Contractors
• Temporary workers
• Agents
• Outsourced service providers acting on behalf of Crest Pay

Every individual acting for Crest Pay must comply with this Policy.

3. Objectives

Crest Pay aims to:

• prevent financial crime;
• identify suspicious activity;
• protect customers and payment partners;
• comply with legal obligations;
• maintain accurate records;
• cooperate with law enforcement and regulatory authorities where required.

4. Risk-Based Approach

Crest Pay adopts a risk-based approach by assessing factors including:

Customer risk

• Nature of business
• Ownership structure
• Beneficial ownership
• Industry sector
• Geographic exposure
• Expected transaction volumes

Transaction risk

• Unusual payment activity
• Large or unexpected transactions
• Rapid movement of funds
• High-risk payment patterns

Geographic risk

Additional scrutiny may be applied where customers or transactions involve jurisdictions identified as presenting higher money laundering or sanctions risks.

5. Customer Due Diligence (CDD)

Before providing services, Crest Pay may require:

• proof of identity;
• proof of address;
• Companies House verification;
• verification of directors;
• verification of beneficial owners;
• VAT registration details;
• source of funds information where appropriate;
• source of wealth information where appropriate.

Services may be delayed or refused where satisfactory verification cannot be completed.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be undertaken where appropriate, including where:

• the customer presents a higher risk;
• the ownership structure is unusually complex;
• Politically Exposed Persons (PEPs) are involved;
• higher-risk jurisdictions are connected to the business;
• unusual transaction patterns are identified.

Enhanced measures may include requesting additional documentation, obtaining senior management approval or conducting more frequent reviews.

7. Ongoing Monitoring

Crest Pay monitors customer relationships throughout their lifecycle. Monitoring may include:

• reviewing transaction patterns;
• verifying changes to customer information;
• identifying unusual activity;
• reviewing payroll funding patterns;
• checking sanctions lists where appropriate.

Where concerns arise, further information may be requested.

8. Sanctions Compliance

Crest Pay will not knowingly provide services to individuals, businesses or organisations that are subject to applicable financial sanctions.

Where required, customers may be screened against relevant sanctions lists before and during the business relationship.

9. Fraud Prevention

Crest Pay maintains procedures designed to detect and prevent fraud, including:

• identity verification;
• secure authentication;
• transaction monitoring;
• staff awareness training;
• internal controls;
• segregation of duties;
• incident reporting procedures.

10. Suspicious Activity

If Crest Pay identifies activity that appears unusual or potentially unlawful, it may:

• request further information;
• temporarily suspend services;
• delay processing while enquiries are made;
• refuse to process a transaction;
• terminate the business relationship where appropriate;
• make reports to the relevant authorities where legally required.

11. Record Keeping

Records relating to customer due diligence, risk assessments and transaction monitoring will be retained for the period required by applicable law or regulatory guidance.

Access to such records will be restricted to authorised personnel.

12. Employee Responsibilities

Employees must:

• comply with this Policy;
• remain alert to unusual activity;
• complete required compliance training;
• report concerns immediately through internal reporting channels;
• protect confidential information.

No employee should ignore suspected financial crime.

13. Training

Appropriate employees will receive periodic training covering:

• anti-money laundering;
• fraud awareness;
• sanctions compliance;
• data protection;
• financial crime prevention;
• internal reporting procedures.

Training records will be maintained.

14. Internal Controls

Crest Pay maintains internal controls including, where appropriate:

• approval limits;
• segregation of duties;
• access controls;
• audit trails;
• secure IT systems;
• periodic compliance reviews.

15. Confidentiality

Information obtained for financial crime prevention purposes will be handled confidentially and disclosed only where necessary to comply with legal or regulatory obligations.

16. Review

This Policy will be reviewed periodically and updated where necessary to reflect changes in legislation, regulation or business operations.

17. Contact

Compliance Officer, Advanced Asset Management Ltd, trading as Crest Pay

Email: info@crestpay.net · Website: www.crestpay.net

Schedule 1 – Indicators of Potential Financial Crime

Examples of activity that may require further review include:

• unexplained changes in transaction patterns;
• unusually large or complex payments;
• inconsistent customer information;
• reluctance to provide requested documentation;
• multiple accounts controlled by the same individual without a clear business purpose;
• transactions that appear inconsistent with the customer's stated business activities.

The presence of one or more indicators does not necessarily mean financial crime has occurred but may justify additional enquiries.

Schedule 2 – Governance

The Board of Directors is responsible for ensuring that appropriate financial crime controls are maintained and that this Policy is reviewed regularly.

Management is responsible for implementing the Policy and ensuring that employees understand and comply with its requirements.