Anti-Money Laundering Policy

Last Updated: 29 May 2025

1. Policy Statement

NOXX & Co maintains zero tolerance towards money laundering, terrorist financing, and related financial crimes. We comply fully with the UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, and all subsequent amendments.
Governance: Our AML programme is overseen by the Principal and Senior Compliance Officer.

2. Client Due Diligence (CDD) Measures

Identification Requirements
All clients must provide:

Certified proof of identity (passport/driving licence)
Verified address documentation (utility bill/bank statement less than 3 months old)
Company incorporation documents (for corporate clients)

Enhanced Due Diligence (EDD)
Applied to:

Politically Exposed Persons (PEPs)
High-risk jurisdictions (per UK Treasury lists)
Transactions exceeding £15,000

3. Ongoing Monitoring

Transaction Screening

Automated monitoring of unusual payment patterns
Manual review for complex transactions

Annual Reviews

Re-verification of client identities
Update of risk assessments

Red Flag Indicators

Requests for unnecessary secrecy
Inconsistent transaction documentation
Use of third parties without clear rationale

LEGAL & COMPLIANCE

Terms & Conditions

Cookie Policy

Client Care Charter

Anti-Money Laundering Policy

Modern Slavery Statement

Quick Contact

4. Reporting Obligations

Internal Procedures

Staff must report suspicious activity immediately to the MLRO
Preliminary investigation within 48 hours
Secure documentation maintained for 7 years

National Crime Agency (NCA) Submissions

Suspicious Activity Reports (SARs) filed when required
No “tipping off” permitted post-filing

5. Staff Training

Mandatory annual AML training for all employees
Specialist workshops for client-facing teams
Testing of knowledge retention

6. Record Keeping

Retention Periods:

Client identification: 7 years post-relationship
Transaction records: 7 years from completion
SAR documentation: Indefinitely

Storage Methods:

Encrypted digital files
Physical documents in secure cabinets

7. Client Cooperation

By engaging our services, clients agree to:

Provide accurate information promptly
Disclose ultimate beneficial owners (UBOs)
Notify us of any changes in circumstances

Right to Refuse Service:
We reserve the right to terminate engagements where AML compliance cannot be assured.

8. Policy Enforcement

Violation Consequences:

Immediate suspension of involved staff
Regulatory reporting where appropriate
Civil/criminal proceedings if warranted

Contact Our Money Laundering Reporting Officer (MLRO):
WAML Queries: info@noxxandco.com (Subject: “AML Enquiry”)
Urgent Concerns: 020 7164 6399 (Ask for MLRO)
Copyright © 2025 NOXX & CO. All rights reserved.