Wild Circle Dynamics LTD is committed to preventing money laundering, terrorist financing, fraud and other financial crime. This Know Your Customer (KYC) and Anti-Money Laundering (AML) Policy sets out the standards and procedures we follow to identify our customers, understand the nature of their business, monitor transactions and report suspicious activity. This policy is designed to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, the Proceeds of Crime Act 2002, the Terrorism Act 2000 and 2006, and guidance issued by the UK Financial Conduct Authority and HM Revenue & Customs where applicable.
1. Policy statement
We take a risk-based approach to preventing money laundering and terrorist financing. We will not knowingly enter into business relationships or process transactions that involve the proceeds of crime or that facilitate terrorist financing. We expect all employees, directors, contractors and business partners to comply with this policy and to report any concerns promptly.
2. Scope
This policy applies to all services provided by Wild Circle Dynamics LTD where there is a risk of money laundering or terrorist financing, including but not limited to:
- payment processing for implementation and consultancy services;
- high-value or recurring business relationships;
- transactions involving customers, suppliers or partners in higher-risk jurisdictions;
- any situation where we become aware of suspicious activity or unusual transaction patterns.
3. Roles and responsibilities
The directors of Wild Circle Dynamics LTD have overall responsibility for ensuring that effective AML/CTF controls are in place. Day-to-day responsibility for implementing this policy is delegated to the nominated officer or compliance lead. All staff are required to:
- understand and comply with this policy;
- carry out customer due diligence as required;
- monitor transactions and customer behaviour for suspicious activity;
- report any suspicions to the nominated officer without tipping off the customer;
- maintain accurate records and cooperate with law enforcement and regulators.
4. Risk assessment
We assess money laundering and terrorist financing risk across our business, products, services, customers and delivery channels. Factors considered include:
- customer type (individual, company, partnership, trust);
- country of incorporation, residence or operation;
- nature and purpose of the business relationship;
- transaction size, volume and frequency;
- use of third parties, intermediaries or anonymous structures;
- any adverse media, sanctions or politically exposed person (PEP) status.
Our risk assessment is reviewed regularly and whenever there are significant changes to our business or the regulatory environment.
5. Customer due diligence (CDD)
We conduct customer due diligence before establishing a business relationship or processing a high-value transaction. The level of due diligence depends on the assessed risk. Standard CDD measures include:
- verifying the customer's identity using reliable and independent sources;
- verifying the legal existence of companies, partnerships or other entities;
- identifying beneficial owners and understanding ownership and control structures;
- understanding the nature and intended purpose of the business relationship;
- obtaining information about the customer's business activities and source of funds;
- screening against sanctions, PEP and adverse media lists.
We may request documents such as passports, driving licences, utility bills, company registration certificates, articles of association, partnership agreements and bank statements.
6. Beneficial ownership
For corporate customers, partnerships, trusts and similar structures, we identify the beneficial owners. A beneficial owner is any individual who ultimately owns or controls 25% or more of the entity, or who exercises control over its management or assets. Where ownership is complex or layered, we take reasonable steps to understand the ownership and control structure.
7. Enhanced due diligence (EDD)
Enhanced due diligence is required in higher-risk situations, including:
- customers based in or connected to high-risk jurisdictions;
- politically exposed persons (PEPs) or their close associates and family members;
- complex ownership structures without clear economic purpose;
- unusually large, frequent or complex transactions without apparent commercial rationale;
- any other situation where standard CDD does not provide sufficient assurance.
EDD measures may include additional identity verification, more detailed understanding of source of funds and wealth, senior management approval, enhanced monitoring and more frequent review.
8. Simplified due diligence (SDD)
Simplified due diligence may be applied where the money laundering and terrorist financing risk is assessed as low, for example when dealing with public bodies or listed companies in the UK or equivalent jurisdictions. SDD does not mean no due diligence; we still verify identity and monitor the relationship, but to a reduced extent.
9. Ongoing monitoring
Customer due diligence is not a one-off exercise. We monitor business relationships and transactions on an ongoing basis to detect suspicious activity. This includes:
- reviewing transactions for consistency with the customer's known business and risk profile;
- identifying unusual patterns, such as unexpectedly large payments, rapid refunds or payments from unrelated accounts;
- keeping customer information up to date;
- re-screening customers against sanctions and adverse media lists on a risk-based basis.
10. Third-party payment processing
Card payments are processed through a third-party payment provider. The provider performs its own identity verification, transaction monitoring and fraud prevention checks. We rely on the provider's systems for the technical processing of card payments but remain responsible for our own AML/CTF compliance, including customer due diligence, risk assessment and suspicious activity reporting.
Where our payment provider flags a transaction as high risk or suspicious, we will review the relationship and may request additional information, delay delivery, refuse the transaction or terminate the business relationship.
11. Suspicious activity and reporting
Staff must report any suspicion of money laundering, terrorist financing or other criminal activity to the nominated officer immediately. The nominated officer will assess whether a Suspicious Activity Report (SAR) should be submitted to the National Crime Agency (NCA).
It is an offence under UK law to "tip off" a customer that a report has been made or that an investigation is underway. Staff must not disclose any such information to the customer or any third party.
12. Record keeping
We keep records of CDD, risk assessments, transaction monitoring, AML decisions and any reports made to the NCA for at least five years after the end of a business relationship, or for five years from the date of a one-off transaction, in line with the Money Laundering Regulations 2017. Records are stored securely and are accessible to relevant staff and regulators.
13. Sanctions and embargoes
We do not conduct business with individuals or entities that are subject to UK, EU, UN or other applicable sanctions, embargoes or trade restrictions. We screen customers, suppliers and related parties against relevant sanctions lists and will not provide services or process payments where a match is confirmed.
14. Politically exposed persons (PEPs)
We identify whether a customer or beneficial owner is a PEP or a close associate or family member of a PEP. PEP relationships require enhanced due diligence and senior management approval before a business relationship can be established.
15. Staff training and awareness
All relevant staff receive AML/CTF training on induction and at regular intervals thereafter. Training covers the legal and regulatory framework, this policy, how to identify suspicious activity, customer due diligence requirements and the importance of reporting concerns. Records of training are maintained.
16. Policy review
This policy is reviewed at least annually and whenever there are significant changes to our business, services, customer base, payment methods or the legal and regulatory environment. Any material changes are approved by the directors.
17. Non-compliance
Failure to comply with this policy may result in disciplinary action, termination of contracts or business relationships, and may be reported to the relevant authorities. We take any breach seriously because money laundering and terrorist financing offences can result in severe criminal and civil penalties for both the company and individuals involved.
18. Contact
If you have any questions about this KYC / AML Policy, or if you need to report a concern, please contact us:
Wild Circle Dynamics LTD
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Company number: 17371923
Email: info@wildcircledynamicsltd.com