Anti-Money Laundering (AML) Policy

Introduction

Online Account Entry (OAE) is firmly committed to preventing its services from being used for money laundering, terrorist financing, or any illegal activity. As a responsible financial services provider operating under Outsource Professional Directors (OPD) Limited, we adhere to the UK Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and all applicable global standards.

Purpose

This policy outlines OAE’s approach to identifying, assessing, and mitigating risks of money laundering and terrorist financing across our operations in the UK, Germany, and Ghana.

Scope

The AML Policy applies to:

• All employees, agents, contractors, and third-party service providers.

• All client relationships, financial transactions, and bookkeeping activities.

Key Objectives

• To comply fully with applicable AML laws and regulations.

• To establish robust client identification and verification procedures.

• To detect and report suspicious activities promptly.

• To maintain accurate records of all financial and client transactions.

Customer Due Diligence (CDD)

OAE conducts thorough Know Your Customer (KYC) checks before establishing any business relationship.
This includes:

• Verifying client identity using government-issued documents.

• Understanding the nature of the client’s business and the transaction purpose.

• Conducting risk-based reviews for politically exposed persons (PEPs) and high-risk clients.

Enhanced Due Diligence (EDD)

For high-risk clients or jurisdictions, enhanced scrutiny is applied through:

• Additional identity verification and source-of-funds documentation.

• Ongoing transaction monitoring for unusual activity.

• Management approval before onboarding.

Monitoring and Reporting

• Continuous transaction monitoring systems are used to detect suspicious behaviour.

• Suspicious Activity Reports (SARs) are filed with relevant authorities, including the UK National Crime Agency (NCA).

• Employees are prohibited from tipping off clients under investigation.

Record Keeping

All CDD and transaction records are retained for a minimum of five (5) years following the end of the business relationship, as required by law.

Training

OAE provides mandatory AML training to all employees to ensure awareness of obligations, red flags, and reporting procedures.

Responsibilities

• The AML Compliance Officer oversees adherence to this policy.

• Employees must report any suspicions immediately to the Compliance Officer.

Non-Compliance

Failure to comply with AML procedures may result in disciplinary action, termination of employment, and potential legal penalties.