01Commitment
Ashcroft has a zero-tolerance approach to money laundering, terrorist financing, bribery, sanctions evasion and market abuse. We comply with the UK Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, FATF Recommendations and equivalent regimes in every jurisdiction in which we operate.
02Governance
Program oversight sits with a designated Money Laundering Reporting Officer (MLRO) who reports quarterly to the board. Policy is reviewed at least annually and after any material regulatory change.
03Client Due Diligence (CDD)
Before onboarding, we verify identity and residence using government-issued ID and independent address evidence, screen beneficial owners against global sanctions and PEP lists (updated hourly), and assess source-of-funds where appropriate. Enhanced due diligence applies to high-risk jurisdictions and PEPs.
04Ongoing Monitoring
Client files are periodically refreshed (annually for standard risk, semi-annually for high risk). Unusual patterns trigger internal escalation to the MLRO.
05Reporting
Suspicious Activity Reports are submitted to the National Crime Agency (or local FIU) where required, and Ashcroft will not "tip off" the subject of a report. Employees are trained to recognise and escalate red flags.
06Record-Keeping
KYC documentation and transaction records are retained for a minimum of 5 years after the end of the business relationship, or longer where required by law.
07Training
All staff complete mandatory AML/CTF training on hire and annually thereafter, with role-specific modules for client-facing analysts.