OUTPOST
Financial Crimes Policy

Financil Crimes Privacy Policy

As of January 21 2022.

Anti Money Laundering and Financial Crime Policy

1. Policy Statement

OUTPOST and its staff are committed to the highest standards of anti-money laundering

(AML), including anti-fraud, anti-corruption and taking measures to mitigate against

financial crime. We abide by and adheres to all applicable laws and regulations regarding

AML in all jurisdictions where it conducts its business. We have developed and

implemented a comprehensive set of measures to identify, manage and control all AML

risks. We understand that the money laundering regulations and legislation place a

responsibility upon OUTPOST employees to combat money laundering with regard to a

wide area of financial transactions, including possessing, or in any way dealing with, or

concealing, the proceeds of any crime.

2. Purpose

The purpose of this policy is to ensure that OUTPOST complies with the obligations and

requirements set out by UK legislation, regulations and rules regarding AML. This includes

ensuring that we have adequate systems and controls in place to mitigate against any risk

posed to the firm and its clients. This policy is also in place to ensure that all employees

know and understand their obligations with regards to our anti-money laundering measures

and the consequences of non-compliance in this area. OUTPOST Management will do

everything possible to protect its staff and clients from being exposed to money laundering

and will comply with the guidance and rules laid out in Money Laundering Regulations

2007, The Proceeds of Crime Act 2002 and the Terrorism Act 2000. Any actual or suspected

acts of money laundering will be reported to the NCA and where applicable to regulatory

requirements, an MLRO will be appointed to oversee all aspects of the anti-money

laundering functions.

3. Scope

The policy relates to all staff (meaning permanent, fixed term, and temporary staff, any

third-party representatives or sub-contractors, agency workers, volunteers, interns and

agents engaged with OUTPOST in the UK or overseas) within the organisation and has been

created to ensure that staff deal with the area that this policy relates to in accordance

with legal, regulatory, contractual and business expectations and requirements. Failure of

any staff member to adhere to the guidance and objectives laid out in this policy, may

lead to disciplinary action.

4. What Is Money Laundering

Money laundering is the term used to describe the process or act of disguising or hiding the

original ownership of money that has been obtained through criminal acts such as

terrorism, corruption, or fraud. Such monies are then moved through legitimate businesses

and sources to make it appear ‘clean’. OUTPOST operates under and complies with the

below laws, Acts and regulations with regards to our Anti-Money Laundering policy and

procedures:

• The Proceeds of Crime Act 2002 (POCA)

• Serious Organised Crime and Police Act 2005 (SOCPA)

• The Terrorism Act 2000, as amended by the:

• The Anti-Terrorism, Crime & Security Act 2001

• Terrorism Act (Amendment) Regulations 2007

• The Terrorism Act 2006

• The Bribery Act 2010

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• The Money Laundering Regulations 2007

• The FCA Handbook

• The Joint Money Laundering Steering Group (JMLSG)

5. Objectives

To prevent financial crime and money laundering within our organisation, OUTPOST aims to

meet the below objectives:

• The reporting and detection of suspected money laundering to the NCA via a SAR

• All staff are trained and must remain vigilant for the signs of money laundering

• No payment of physical cash will be accepted by the company if it exceeds £2,000.

• Due diligence and client identification procedures will be followed by all staff and at all

times

• Frequent risk assessment and audits of all AML and terrorist financing controls and systems

• To appoint a Money Laundering Reporting Officer with sufficient knowledge and seniority

as to complete the tasks and objectives laid out in this document

• Maintain client identification procedures in all circumstances

• Implement procedures to enable the reporting of suspicions of money laundering

• Maintain record keeping procedures

• Utilise an employee screening program to ensure due diligence

5.1 Anti-Bribery & Anti-Corruption

OUTPOST operates a zero-tolerance policy with regards to bribery and corruption and

realise that impact that bribery and corruption have on the money laundering

requirements. As bribery and corruption are often associated with organised crime and/or

money laundering, we are committed to applying high standards of honesty and integrity

throughout our organisation and ensure that all staff operate in accordance with the

intent.

6. Procedures

OUTPOST adheres to and complies with the principles of the Know Your Customer policy

which aims to prevent financial crime and money laundering through client identification

and due diligence. All customers/clients who are new to the organisation will undergo

procedural due diligence checks prior to opening an account, as laid out below:

6.1. Identification

Proof of who an individual or business is will be gained and recorded on a New Customer

Application. Two forms of ID are required with the person/business name on and 1 form of

ID with the trading/home address. Acceptable forms of ID can include:

• Individual – Drivers Licence, Passport, Bank Statement, Utility Bill

• Business – Director/Proprietor ID, Certificate of Incorporation, Company Registration

Number & Registered Office, Utility Bill, Supplier Invoice, Bank Statement

This process is carried out by an external supplier: Veri-Check. Veri-Check are a GDPRapproved resident identification company and will hold details securely on file on behalf of

OUTPOST.

6.2. Due Diligence Checks

For businesses, credit and company background checks will be performed prior to account

acceptance, details of which will be kept on file as evidence of due diligence and antimoney laundering checks. Due diligence checks are obligatory in the UK when a single

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transaction exceeds EUR15,000 or where doubt exists about the identity or reliability of the

customer.

7. Measures to Prevent Money Laundering

There are certain measures and controls that can be implemented and carried out to help

prevent against money laundering. OUTPOST carries out such measures in the course of its

daily business activities and is committed to preventing any aspect of financial crime.

7.1 Client Identification Procedures – as set out in clause 6 of this policy, client ID and due

diligence is performed on new customers and where legal or regulatory standards require.

7.2 Vendor Declaration – Vendors are asked to contractually certify they will follow high

standards of conduct that align with Outpost’s Code of Conduct, including anti-bribery

and anti-corruption representations.

7.3 Traceable Transactions – all transactions carried out by OUTPOST recorded in such a

manner that their origin can be traced should the need arise.

7.4 Records Management – all documents, accounts and transactions associated with

clients/customers will be retained as per the legal or statutory retention periods, which

currently stands at ‘Close of Account +3 Years’.

7.5 Reporting –All documents relating to money laundering reporting, business transactions,

client identification and customer due diligence are retained for a minimum of 3 years. We

will ensure that the below minimums are met with regards to the information disclosed on

any reports:

• Full details of the people involved

• Full details of the nature of their/your involvement

• The types of money laundering activity involved

• The dates of such activities

• Whether the transactions have happened, are ongoing or are imminent

• Where they took place

• How they were undertaken

• The approx./exact amount of money/assets involved;

• What has given rise to the suspicion

Using all of the information available at the time, the CEO will make an informed decision

using sound judgment as to whether there are reasonable grounds for knowledge or

suspicion of money laundering and to enable them to prepare their report for the National

Crime Agency (NCA), where appropriate.

7.6 Ongoing Due Diligence – the Operations Director is responsible for conducting ongoing

due diligence checks for the life of the client/customer account, ensuring that all

information is kept up-to-date and that no adverse information has arisen since the last

monitoring check was performed. Such checks are to be performed on all existing, active

customers on a rolling annual basis.

8. Training

OUTPOST has implemented a comprehensive Anti-Money Laundering and Financial Crime

training program to ensure that all staff, in particular individuals responsible for transaction

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processing and/or initiating and/or establishing business relationships, undergo AML

knowledge, competency and awareness training. Training methods and sessions are

tailored to the business to ensure that staff are aware of the different possible patterns and

techniques of money laundering that could occur in their everyday duties and roles. This

training is provided online, at the point of onboarding, and renewed annually. OUTPOST’S

training partner, Cardinus Risk Management, provides up to date information, applicable

to the country in which it is given.

9. Responsibilities

9.1 OUTPOST will appoint an MLRO where regulatory or legally required and will comply with

all UK legislation and regulations regarding the prevention and mitigation of money

laundering.

9.2 OUTPOST will ensure that all staff are provided with the time, resources and support to

learn, understand and implement processes and actions to prevent money laundering and

will be expected to be vigilant at all times with respect to any acts of suspected financial

crime. Any suspicions are to be reported to the MRLO immediately.

9.3 The MRLO will ensure that any actual or suspected case of money laundering is detailed

on a Suspicious Activity Report (SAR) and is reported to the National Crime Agency (NCA)

with immediate effect.

10. MONEY LAUNDERING REPORTING OFFICER (MLRO)

10.1 NOMINATED REPORTING OFFICER

NAME: _____________________________________________

POSITION: __________________________________________

ADDRESS: __________________________________________

EMAIL: ____________________________________________

TEL: ______________________________________________

10.2 DEPUTY REPORTING OFFICER

NAME: _____________________________________________

POSITION: __________________________________________

ADDRESS: __________________________________________

EMAIL: ____________________________________________

TEL: _____________________________________________