Money laundering is defined as the process where the identity of the proceeds of crime are so disguised that it gives the appearance of legitimate income. Criminals specifically target financial services firms through which they attempt to launder criminal proceeds without the firm's knowledge or suspicions.
Within the UK alone it is estimated that approximately 23 billion is laundered on an annual basis and on globally in revenue terms the amount of money laundered would make it the third largest industry.
In response to the scale and effect of money laundering the United Kingdom, in common with many other countries, has passed legislation designed to prevent money laundering and to combat terrorism. This legislation, together with regulations, rules and industry guidance, forms the cornerstone of AML/CTF obligations for UK firms and outline the offences and penalties for failing to comply.
Whilst MIDDLEC are currently unregulated and do not fall with the scope of the AML/CTF obligations in the UK the senior management have implemented systems and procedures that meet the UK AML legislation. This decision reflects the senior managements desire to prevent money laundering and not be used by criminals to launder proceeds of crime.
UK AML LEGAL AND REGULATORY FRAMEWORK:
The UK AML regime is set out in the following legislation and regulations:
ANTI-MONEY LAUNDERING (AML) POLICY:
The MiddleC AML Policy is designed to prevent money laundering by meeting the UK AML legislation obligations including the need to have adequate systems and controls in place to mitigate the risk of the firm being used to facilitate financial crime. This AML Policy sets out the minimum standards which must be complied with and includes:
MiddleC is prohibited from transacting with individuals, companies and countries that are on prescribed Sanctions lists. MiddleC will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate.