AML Policy
1. Introduction
Cocoon Vehicles Ltd (“the Company”) is committed to preventing money laundering, terrorist financing, and other financial crimes. This Anti-Money Laundering (AML) Policy outlines the Company’s approach to detecting and mitigating risks associated with financial crime, ensuring compliance with the UK’s regulatory framework, including the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, and guidance issued by the Financial Conduct Authority (FCA).
2. Purpose
The purpose of this policy is to:
Establish procedures for identifying and reporting suspicious activities.
Ensure compliance with legal and regulatory requirements.
Protect the Company from being used as a vehicle for money laundering.
Promote a culture of compliance and ethical business conduct.
3. Responsibilities
3.1 Money Laundering Reporting Officer (MLRO)
The Company shall appoint a Money Laundering Reporting Officer (MLRO) responsible for overseeing AML compliance, reviewing suspicious activity reports (SARs), and liaising with relevant authorities.
3.2 Employee Responsibilities
All employees must be aware of this policy and comply with its provisions. Employees must report any suspicious activities to the MLRO immediately.
4. Customer Due Diligence (CDD)
Cocoon Vehicles Ltd will conduct due diligence on all customers to verify their identity and assess the risks of money laundering. CDD procedures include:
Obtaining and verifying customer identification (e.g., passport, driving licence, utility bill).
Conducting risk assessments to determine the level of due diligence required.
Enhanced Due Diligence (EDD) for high-risk customers, including politically exposed persons (PEPs).
5. Reporting Suspicious Activity
If an employee suspects that a transaction may involve money laundering or other financial crimes, they must:
Report their concerns to the MLRO.
The MLRO will assess the report and, if necessary, file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).
No action should be taken that could alert the customer to the report (tipping-off is a criminal offence).
6. Record-Keeping
The Company will maintain records of customer due diligence checks, transactions, and reports of suspicious activity for a minimum of five years, as required by law. Our company policy is seven years.
7. Staff Training
All employees must undergo regular AML training to recognise suspicious activities and understand their obligations under this policy. Training will be provided at least annually and upon joining the Company.
8. Monitoring and Review
The AML policy will be reviewed annually to ensure its effectiveness and compliance with regulatory changes. Updates will be communicated to all employees as necessary.
9. Consequences of Non-Compliance
Failure to comply with this policy may result in disciplinary action, up to and including termination of employment, and could lead to legal consequences for both the individual and the Company.
Approved by
The Board of Directors