Anti-Money Laundering Policy

Scope

This policy applies to Griffin James Limited and all employees, contractors and agents involved in the valuation, disposal and sale of tangible and intangible assets, including work undertaken as an agent for insolvency practitioners. It sets out the firm's approach to preventing money laundering, terrorist financing and sanctions violations in compliance with UK legislation and professional standards.

1. Legal Framework

Griffin James operates under a robust legislative framework. The principal UK statutes and regulations governing money laundering and terrorist financing include:

• Proceeds of Crime Act 2002 (POCA) – establishes substantive money‑laundering offences such as concealing, transferring or acquiring criminal property.
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended – impose requirements on "relevant firms" to apply risk‑based customer due‑diligence, record‑keeping and reporting measures.
• Terrorism Act 2000 and Sanctions and Anti‑Money Laundering Act 2018 – provide offences relating to terrorist financing and allow the UK to impose sanctions regimes.
• Financial sanctions regime – Insolvency practitioners are subject to sanctions reporting obligations from 14 May 2025. The Office of Financial Sanctions Implementation (OFSI) publishes lists of designated persons and entities subject to asset freezes and other restrictions.
• Estate agency & auctioneering regulation – HMRC supervises estate agency and certain auction businesses under the Money Laundering Regulations. It is a criminal offence to trade as an estate agency business without being registered for AML supervision. Asset management businesses that provide estate agency or auction services, as well as business brokers and transfer agents, must register.

Griffin James is a RICS‑regulated firm and adheres to the Royal Institution of Chartered Surveyors' professional standards on countering bribery, corruption, money laundering and terrorist financing. We also follow guidance issued by insolvency professional bodies and HMRC.

2. Policy Statement and Objectives

Griffin James is committed to preventing its services from being used to facilitate money laundering, terrorist financing or sanctions breaches. We take a risk‑based approach to customer due diligence, monitor transactions and report suspicious activity. Our objectives are to:

• • Comply with all applicable AML/CTF laws and regulations.
• • Identify, assess and mitigate the risk of money laundering and terrorist financing associated with clients, transactions and asset classes.
• • Conduct appropriate customer due diligence (CDD) and enhanced due diligence (EDD) where required.
• • Report suspicions to the National Crime Agency (NCA) via Suspicious Activity Reports (SARs) and co‑operate with law enforcement.
• • Screen clients and counterparties against financial sanctions lists and Politically Exposed Persons (PEP) databases.
• • Maintain comprehensive records and ensure ongoing staff training.

3. Roles and Responsibilities

4. Risk Assessment

Griffin James conducts a documented risk assessment to identify the money‑laundering and terrorist‑financing risks associated with its services, clients, transactions and delivery channels. Factors considered include:

• • Client risk – type of client (individual, corporate, insolvency practitioner), geographic location, involvement of PEPs, nature of the business and insolvency status.
• • Product/Service risk – complexity and value of assets (e.g. high‑value machinery, intellectual property), potential for ownership opacity, or involvement of cash transactions.
• • Delivery channel – face‑to‑face interactions versus remote instructions, use of intermediaries, involvement of multiple jurisdictions.
• • Transactional risk – urgency, source of funds, unusual payment methods or structures.

The risk assessment is reviewed annually or when new products, services or regulations emerge.

5. Customer Due Diligence (CDD)

Griffin James applies CDD measures before establishing a business relationship or carrying out a transaction. This includes:

• • Client identification and verification – obtaining the client's full name, address, date of birth (for individuals), company registration details and verifying these against reliable, independent sources (e.g. identity documents, Companies House records).
• • Beneficial ownership – identifying and verifying the ultimate beneficial owners of corporate clients, trusts or partnerships to understand who ultimately owns or controls the entity.
• • Purpose and nature of relationship – obtaining information on the purpose of the engagement, source of funds and expected transaction values to assess risk.
• • Screening – checking clients and beneficial owners against sanctions lists published by OFSI and other relevant authorities and screening for PEPs or adverse media. High‑risk clients require senior management approval.
• • Enhanced due diligence (EDD) – applied where clients or transactions present a higher risk (e.g. complex ownership structures, high‑value sales, clients from high‑risk jurisdictions). EDD may include obtaining additional information on the source of wealth, verifying identities via multiple documents or using independent verification services.

No transactions will be conducted until CDD has been satisfactorily completed and the MLRO has approved the engagement.

6. Ongoing Monitoring

Once engaged, Griffin James monitors client relationships and transactions to ensure they remain consistent with the information obtained during CDD. This includes:

• • Reviewing transaction patterns for discrepancies with expected behaviour.
• • Refreshing CDD information periodically and when circumstances change.
• • Ensuring that sales proceeds are paid into accounts in the names of verified clients and that payments are not made to unrelated third parties without proper justification.
• • Escalating unusual or suspicious activity to the MLRO.

7. Record Keeping

In line with the Money Laundering Regulations, Griffin James keeps records of:

• • Client identification and verification documents.
• • Risk assessments and due diligence information.
• • Asset valuation and sale documentation.
• • Records of transactions, including invoices, contracts, payment instructions and receipts.
• • Internal suspicion reports, SARs and any correspondence with the NCA or OFSI.

Records are retained for at least five years from the end of the business relationship or the completion of the transaction, whichever is later. Personal data is handled in accordance with the UK General Data Protection Regulation (GDPR) and relevant data‑protection policies.

8. Reporting Suspicious Activity

All employees and agents must be vigilant and report any suspected money‑laundering or terrorist‑financing activity to the MLRO as soon as possible. Examples include:

• • Transactions that appear inconsistent with a client's known legitimate business.
• • Attempts to conceal beneficial ownership or unwillingness to provide identification documents.
• • Use of complex or unnecessary payment structures.

The MLRO will review the report and decide whether a Suspicious Activity Report (SAR) should be filed with the NCA. Where appropriate, the MLRO may request a defence against money laundering (DAML) from the NCA before proceeding with a transaction. Staff must not warn the client (no "tipping off") as this could constitute a criminal offence under POCA.

9. Sanctions Compliance

Griffin James checks clients and counterparties against UK consolidated sanctions lists maintained by OFSI. If a client or beneficial owner is a designated person or subject to asset‑freeze restrictions, the firm will:

• • Freeze any assets it holds on behalf of the designated person.
• • Avoid making funds or economic resources available to the designated person without a licence.
• • Report the match to OFSI and the MLRO will determine whether a SAR is required.

Sanctions checks are repeated periodically to capture updates. From 14 May 2025, insolvency practitioners and their agents are required to report breaches of financial sanctions to OFSI.

10. Training and Awareness

Griffin James provides regular AML/CTF training to all staff and agents. Training covers:

• • Legal obligations under POCA, Money Laundering Regulations and sanctions laws.
• • Identifying and assessing money‑laundering risks in asset valuation and insolvency contexts.
• • Performing CDD and EDD effectively.
• • Recognising and reporting suspicious activity.
• • Consequences of non‑compliance, including criminal offences and regulatory sanctions.

Training records are maintained and reviewed annually. New employees receive induction training before carrying out regulated activities.

11. Internal Controls and Review

12. Breaches and Disciplinary Action

Non‑compliance with this policy may lead to disciplinary action, including termination of employment or contract. Breaches may also expose individuals to criminal prosecution and the firm to regulatory sanctions. Senior management and the MLRO will investigate all breaches and take appropriate corrective action.

13. Policy Review

This policy will be reviewed at least annually and immediately following any significant legislative or regulatory changes. Updates are approved by the Board and communicated to all employees and agents. The MLRO is responsible for ensuring that the policy remains effective and fit for purpose.