Q4 GROUP IT ART 2011

Anti Money Laundering

Anti-Money Laundering & Counter Terrorist Financing
Policy


This policy sets out the principles and practices designed to deter, detect and disclose to the relevant
authorities those suspected of laundering the proceeds of crime or those involved in the funding or
execution of terrorism. Money laundering refers to the concealment, acquisition, use or possession of
criminal property. For example, a customer/colleague credits their bank account with a payment which
has been obtained through illegal means such as the sale of stolen goods.

All colleagues have a moral and social responsibility to deter and detect the movement of criminal funds
and funds designed to finance terrorism. These obligations are taken very seriously.

Whilst this policy may have a limited impact on Group IT colleagues, it is important colleagues are aware
of the policy, its purpose and specific requirements.

YOUR RESPONSIBILITIES
Full details on colleague responsibilities are set out in the Anti-Money Laundering & Counter Terrorist
Financing Policy document. Below is a summary of the key requirement that affect Group IT colleagues.

ALL COLLEAGUES
All colleagues are expected to act with the utmost integrity at all times.
You must understand and follow local procedures to deter, detect and report suspicious activity or
the funding of terrorism which are relevant to your role and operating environment
You must report any instances of actual or suspected money laundering activity or any request made
to you to undertake activities that would facilitate this, to your line manager. Where you feel unable
to report concerns through your line management, use the Groups established whistleblowing
process [see Whistleblowing Detailed Group Policy]
Apply all procedures and practices in your area of work that mitigate financial crime risk.

MANAGEMENT
Ensure compliance with requirements of this policy by;
Implementing policy awareness and ensuring colleagues receive appropriate role specific training
Identify and assess Anti Money Laundering risks associated with processes and systems and apply
and monitor appropriate mitigations in consultation with Group IT Risk
o Group IT Risk Mailbox
Ensure suspected activity of involving financial crime is fully investigated and reported to Group IT
Risk who will engage with the Nominated Officer and Group Financial Crime.

THE REPORTING PROCESS
Colleagues must report any instances of actual or suspicious Money Laundering activity to their line
manager.
1. Colleague must then document suspicion and notify Group IT Risk via the Money Laundering
Disclosure Form.
2. Group Operations Risk review documented suspicion and engage Group Financial Crime.
3. Further investigations and action plans are agreed between the business, Group Operations Risk and
Group Financial Crime.



FURTHER INFORMATION
For additional guidance referred to in this policy refer to the Minimum Standards and Additional
Information.