AML Policy
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Our Obligations
Eighth Heaven Sourcing Ltd is supervised by HMRC for Anti-Money Laundering (AML) purposes under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. We are legally required to conduct due diligence on all parties we work with before any transaction proceeds.
Customer Due Diligence
All investors are required to complete AML and Know Your Customer (KYC) verification before receiving any deal opportunity. This includes identity verification (government-issued photo ID), proof of address, and evidence of the source of funds intended for investment. We use Credas, a regulated identity verification platform, to assist with this process.
Enhanced Due Diligence
In certain circumstances — including but not limited to high-value transactions, politically exposed persons (PEPs), or higher-risk jurisdictions — we are required to conduct Enhanced Due Diligence (EDD). We reserve the right to request additional documentation as required.
Ongoing Monitoring
We conduct ongoing monitoring of business relationships in line with our regulatory obligations. This includes keeping client records up to date and reviewing the nature and purpose of the business relationship on a risk-sensitive basis.
Suspicious Activity Reporting
Where we have reasonable grounds to suspect money laundering or terrorist financing, we are legally required to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA). We are prohibited by law from disclosing (tipping off) any party that such a report has been made.
Record Keeping
We retain all AML and KYC-related records for a minimum of five years from the end of the business relationship, in compliance with HMRC requirements.
Staff Training
All relevant staff and associates are trained to recognise signs of money laundering and understand their obligations under the Regulations. Training is reviewed and updated regularly.
Legal Note
This AML policy is provided for general information. It must be reviewed and approved by a qualified compliance professional or legal counsel. Eighth Heaven Sourcing Ltd takes its AML obligations seriously and will not engage with parties unwilling to complete the required checks.
For any queries regarding this document, please contact us at info@eighthheavensourcing.com.