Anti-Money Laundering Policy

Anti-Money Laundering (AML) Policy for Outsourcing Professional Directors (OPD) Limited, aligned with UK regulatory standards:

Outsourcing Professional Directors (OPD) Limited
Anti-Money Laundering (AML) Policy
Effective Date: August 2025
Approved by: Sarah Santeng, Chief Executive Director

1. Policy Statement

Outsourcing Professional Directors (OPD) Limited is committed to conducting its business by all applicable anti-money laundering (AML) laws and regulations, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended.

We take a zero-tolerance approach to money laundering and terrorist financing and are dedicated to identifying and preventing the use of our services for illegal or illicit purposes.

2. Purpose

This policy outlines our procedures for preventing money laundering and ensuring compliance with UK regulatory requirements. It also demonstrates our commitment to safeguarding the integrity of our business and the financial system at large.

3. Scope

This policy applies to all OPD operations, including our services in:

• Outsourcing payroll management

• Outsourcing bookkeeping

• Outsourcing personnel and expats' services

• Charity and church management

• Umbrella company operations

• Training and recruitment services

It applies to all staff, contractors, partners, and clients engaged with OPD.

4. Definition of Money Laundering

Money laundering refers to the process by which criminals disguise the original ownership and control of the proceeds of criminal conduct. It typically involves three stages:

• Placement: Introducing illicit funds into the financial system

• Layering: Concealing the source through complex transactions

• Integration: Reintroducing laundered money into the legitimate economy

5. AML Roles and Responsibilities

• Chief Executive Director – Overall responsibility for AML compliance

• Money Laundering Reporting Officer (MLRO) – [Insert Name], responsible for receiving internal suspicious activity reports (SARs) and reporting to the National Crime Agency (NCA)

• All Staff – Required to understand and comply with AML obligations, complete mandatory training, and report suspicious activity

6. Customer Due Diligence (CDD)

We perform CDD on all clients and suppliers before establishing any business relationship. This includes:

• Verifying identity and address using reliable, independent documentation

• Understanding the nature and purpose of the business relationship

• Conducting enhanced due diligence where there is a higher risk (e.g. politically exposed persons or non-UK-based clients)

7. Ongoing Monitoring

We continuously monitor transactions and business relationships to identify unusual or suspicious activity. Red flags include:

• Inconsistent payment patterns

• Use of shell companies or opaque ownership structures

• Requests to bypass normal procedures or due diligence

• Unexplained source of funds

8. Record-Keeping

We maintain AML records by regulatory requirements, including:

• Identification and verification documents

• Transaction histories and correspondence

• Suspicious activity reports (SARs)

All records are retained for a minimum of five years after the end of the business relationship.

9. Reporting Suspicious Activity

All staff are required to report any knowledge or suspicion of money laundering to the MLRO without delay. The MLRO will assess the report and, if necessary, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

Staff must not inform the subject of a SAR (this is considered tipping off and is a criminal offence).

10. Training and Awareness

AML training is mandatory for all OPD staff and contractors. It includes:

• Recognising red flags

• Understanding legal obligations

• Procedures for internal reporting

Refresher training is provided annually or when regulatory changes occur.

11. Policy Review

This policy is reviewed annually or in response to significant legal or operational changes. Any updates will be approved by senior management.

12. Contact Information

For AML queries or to report suspicious activity, contact:

Money Laundering Reporting Officer (MLRO)
Outsourcing Professional Directors (OPD) Limited
Ability House
121 Brooker Road
Waltham Abbey, EN9 1JH
United Kingdom
📧 info@outsourcedirectors.com
📞 +44 208 145 3355

Approved by: Sarah Santeng
Position: Chief Executive Director
Date: August 2025