🛡️Anti-Money Laundering Policy (Web Version)
1. About This Policy
Eighth Heaven Sourcing Ltd is committed to full compliance with the Money Laundering Regulations 2017 (as amended). We take all necessary steps to prevent money laundering and terrorist financing.
We are registered with HMRC for AML Supervision.
2. Money Laundering Reporting Officer (MLRO)
Our nominated MLRO is:
Yuriy Boykov
📧 Email: info@eighthheavensourcing.com
Their duties include reviewing all suspicions and reporting them to the National Crime Agency (NCA) where required.
3. Risk-Based Approach
We classify clients as either:
- Low Risk: Basic due diligence applies
- High Risk: Enhanced due diligence (EDD), additional documents, certified IDs
We assess every client before starting a business relationship.
4. Due Diligence – What We Collect
For Individual Buyers or Sellers:
- Proof of ID (Passport or Driving Licence)
- Proof of Address (utility bill less than 3 months old)
- Evidence of source of funds (bank statements, etc.)
- Legal ownership confirmation (e.g. Land Registry, power of attorney)
For Corporate Clients:
- Company registration details
- Company address
- Identification of any person with 25%+ shareholding
- Authority documents (e.g. Director identity and authority to act)
We use Credas and Etsos electronic checks (Experian-based) for compliance.
5. Staff Training
- All staff receive AML training upon onboarding and yearly thereafter
- Training is monitored and updated as laws change
- Staff must report any suspicious activity to the MLRO immediately
6. Record Keeping
- All AML-related records are kept securely
- Records are held for 5 years from the end of the business relationship
- Includes ID documents, communications, and evidence of source of funds
7. Reporting Suspicious Activity
We have a legal obligation to report to the NCA if we suspect:
- Money laundering
- Terrorist financing
- Suspicious or unexplained transactions
If a report is made, we may not be able to inform you due to tipping-off laws.
8. Policy Review
We review our AML policy:
- At least annually
- Immediately after changes in law or guidance from HMRC, NCA, or the ICO
9. Contacting Us
For AML-related queries:
📧 Email: info@eighthheavensourcing.com
10. Accessing Our Full AML Policy
For detailed procedures, you may:
- đź“Ž Download the Full AML Policy (PDF)
- đź“© Or request a copy by emailing info@eighthheavensourcing.com