Anti-Money Laundering & Anti-Corruption Policy

Purpose

This policy sets out how SUI Securities Ltd prevents the use of our firm for money laundering, terrorist financing, bribery and other financial crime. It applies to everyone who works for or on behalf of the firm, including partners, employees and appointed representatives.

Our commitment

We act honestly and with integrity in every client relationship and business dealing. We do not accept business we cannot explain, we do not pay or receive bribes in any form, and we co-operate fully with the Financial Conduct Authority, the National Crime Agency and other authorities.

Knowing our clients

Before we act for a client, and at intervals afterwards, we establish who the client is, who ultimately owns or controls any entity involved, and where the money has come from. We ask for independent evidence, we record what we have seen, and we update that information when circumstances change.

• Identification of each client and, where relevant, each beneficial owner.
• Understanding of the purpose and intended nature of the relationship, including the source of funds and source of wealth.
• Enhanced checks where the risk is higher, for example politically exposed persons, complex ownership structures or payments from unfamiliar jurisdictions.

Monitoring and reporting

We keep records of client transactions and payments and review them for anything unusual. Where we know or suspect money laundering, terrorist financing or bribery, we report it to our nominated officer, who decides whether a report to the National Crime Agency is required. We do not tell the client that a report has been made.

Bribery and corruption

We have a zero-tolerance approach to bribery and corruption. We never offer, promise, give or accept a financial or other advantage to obtain or keep business. Gifts and hospitality must be modest, infrequent, properly recorded and never intended to influence a decision. Facilitation payments are prohibited without exception.

Third parties and suppliers

We apply the same standards to the firms we work with. Before we appoint an intermediary, adviser or supplier, we consider its ownership, reputation and controls, and we expect it to hold equivalent anti-money laundering and anti-bribery arrangements.

Training and records

Everyone at the firm receives training on financial crime when they join and at least annually afterwards. Client identification records and transaction records are kept for at least five years after the relationship ends, as the regulations require.

Raising a concern

If you are concerned that money laundering, bribery or other financial crime is connected with our business, tell us through the contact form on our homepage. Concerns are treated confidentially, and no one is penalised for raising one in good faith.

Review

This policy is reviewed at least annually and updated when the regulations, our clients or our business change materially.