Anti-Money Laundering & Countering Terrorist Financing (“AML & CTF”)

Fairmay has implemented systems and controls including but not limited to the following:

  • AML & CTF Policy and underlying procedures
  • Identification & verification of our customers (and beneficial owners where applicable)
  • Identification and risk assessment of any Politically Exposed Persons (“PEPs”)
  • Application of enhanced due diligence for high-risk customers
  • Screening all customers and relevant counterparties against the relevant sanction(s) lists
  • Ongoing monitoring of our customers throughout their relationship lifecycle
  • Procedures for reporting suspicious activities
  • Retaining records in line with our Data Retention Policy
  • Training & awareness to all Fairmay employees   
  • Independent assurance testing  

 

Regulatory Framework

Fairmay’s AML & CTF systems & controls are in adherence with the core regulations listed below:  

  • Money Laundering and Terrorist Financing Regulations 2017 (as amended)
  • Criminal Finances Act 2017
  • Proceeds of Crime Act 2002 (as amended)
  • Counterterrorism (Sanctions) (EU Exit) Regulations 2019
  • Terrorism Act 2000 (as amended by the Anti-terrorism, Crime and Security Act 2001)
  • Counter-terrorism Act 2008, Schedule 7
  • FCA Handbook 
  • HM Treasury Sanctions Notices and News Releases
  • Tertiary Guidance – Joint Money Laundering Steering Group (“JMLSG”)  

Where Fairmay operates in a jurisdiction outside of the UK and where there is a deviation in regulatory requirements, the highest standard will be adopted and prevail across all jurisdictions.   

Sanctions  

Fairmay has procedures in place that adhere with both UK and EU requirements as well as undertaking screening in compliance with US sanctions regimes.  

Fairmay strictly prohibits offering products & services in any jurisdiction that would be deemed as a circumvention of the relevant sanction’s regime.

Fairmay will freeze any accounts held by a UK or EU designated person and in line with the revelation regulations. 

Fairmay is not owned or controlled by any person(s) subject to the relevant sanctions regime.