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Financial Crime & AML Policy

1 – Policy Statement

Faciit Technologies Ltd is committed to identifying, preventing, and reporting financial crime.

As an authorised FCA regulated credit broker, we ensure that our people, systems, and processes are equipped to prevent money laundering, fraud, terrorist financing, bribery, and sanctions breaches.

This policy explains how Faciit complies with the Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Bribery Act 2010, the Economic Crime and Corporate Transparency Act 2023, and applicable FCA guidance including SYSC 6.3 and the Financial Crime Guide (FCG).

2 – Scope and Application

This policy applies to all Faciit employees, directors, consultants, contractors, and third-party service providers who act on behalf of Faciit in any capacity. Everyone is expected to be alert to the risks of financial crime and to follow Faciit's procedures, controls, and training requirements.

Failure to comply may lead to disciplinary action and potential regulatory reporting.

3 – Regulatory Background

Faciit's financial crime obligations derive from UK legislation and guidance, including:

4 – Money Laundering and Terrorist Financing Risks

Money laundering involves concealing the source of criminal funds. Terrorist financing includes the use of both legal and illegal funds to support terrorism. These activities threaten financial systems and consumer trust.

Money laundering is the term used to describe the process or act of disguising or hiding the original ownership of money that has been obtained through criminal acts such as terrorism, corruption or fraud.

Such monies are then moved through legitimate businesses and sources to make it appear 'clean'.

Stages of Money Laundering:

  1. Placement – Criminal funds enter the financial system.
  2. Layering – Complex transactions hide the origin of funds.
  3. Integration – Funds appear legitimate and re-enter the economy.

High-Risk Areas for Faciit:

5 – Governance and Responsibilities

Money Laundering Reporting Officer (MLRO/Nominated Officer)

Faciit's MLRO/Nominated Officer is responsible for:

Board and Senior Management

All Staff

6 – Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

CDD Requirements

Faciit verifies identity and checks sanctions and PEP (politically exposed person) status before onboarding customers (in partnership with the lenders that it introduces customers to). This is supported through digital KYC and Open Banking integrations.

As a credit broker, Faciit assists with the collection and verification of identity information, but ultimate responsibility for onboarding and credit decisions lies with the relevant lender.

EDD Triggers

Enhanced due diligence is applied to:

EDD measures may include:

7 – Suspicious Activity and Fraud Reporting

Red Flags

Our risk based approach therefore includes:

Reporting Procedure

Using all the information available at the time, we will make an informed decision using sound judgment as to whether there are reasonable grounds for knowledge or suspicion of money laundering and to enable them to prepare their report for the NCA where appropriate.

Any employee who suspects financial crime, including money laundering, fraud, or bribery, must report their suspicions promptly to senior management. Upon receipt, senior management will evaluate the report and, if necessary, report the matter to the NCA.

No further enquiries or steps in related transactions should be taken without authorisation from Senior Management. Employees must not disclose suspicions to others, as this may alert suspects and prejudice investigations.

SARs will be assessed and, where appropriate, reported to the NCA. Records are maintained securely for at least 5 years.

8 – Sanctions Compliance

Faciit (in partnership with the lenders that it introduces customer to) screens all customers against:

If a match is identified, onboarding is suspended and escalated to the MLRO/Nominated Officer for further investigation, in partnership with our panel lenders.

9 – Anti-Bribery and Corruption Measures

Bribery is offering, giving, receiving, or soliciting something of value to influence the actions of an individual in a position of trust. Corruption is the abuse of entrusted power for private gain and may include bribery. Examples of bribes include:

Faciit has a zero-tolerance policy for bribery and corruption. The following are prohibited:

Risk-based due diligence is conducted on partners, suppliers, and introducers in order to mitigate the risk of the firm becoming involved in unacceptable practices in this regard.

10 – Training and Awareness

We have implemented Anti-Money Laundering and Financial Crime training to ensure that all staff undergo AML knowledge and awareness training.

Our Financial Crime training program ensures that all employees are confident and competent in the risk assessment and prevention of money laundering and financial crime, and are made aware of the associated regulations relating to money laundering and terrorist financing.

All employees must complete annual training covering:

Staff in high-risk roles receive additional targeted training.

11 – Record Keeping

Faciit retains the following for a minimum of five years:

Records are stored securely and may be made available to regulators upon request.

12 – Monitoring and Internal Audit

The MLRO/Nominated Officer reviews internal controls and conducts annual financial crime risk assessments. Any deficiencies are reported to the Board with remediation actions assigned.

Management Information (MI) is produced quarterly, covering:

13 – Policy Review

This policy is reviewed at least annually or upon any regulatory or legislative change. Revisions are approved by the firm's SMF16 holder and recorded in the version history.