Anti Money Laundering Policy
1. Policy Statement & Objective
IM Power plc is committed to the highest standards of financial integrity, transparency, and legal compliance. This policy establishes an internal framework to prevent our services, platform, or entities from being used for money laundering, terrorist financing, or proliferation financing. We maintain a zero-tolerance stance toward financial crime. Any breach of this policy may lead to internal disciplinary actions or criminal prosecution.
2. Scope
This policy applies universally across our business operations. It is binding for:
All full-time, part-time, and temporary employees.
Board members and corporate executives.
Subsidiaries, contractors, consultants, and third-party partners.
3. Key Roles & Responsibilities
Senior Management: Holds ultimate responsibility for ensuring adequate resources and controls exist to mitigate AML risks.
Money Laundering Reporting Officer (MLRO): Appointed to oversee daily AML compliance, manage internal alerts, and report suspicious activities to financial authorities.
Employees: Required to complete mandatory training, conduct proper client vetting, and immediately escalate suspicious behaviour.
4. Risk-Based Approach (RBA)
The company assesses and classifies money laundering risks on an ongoing basis. Controls are adjusted according to the risk level identified across four areas:
Geographic Risk: Clients from high-risk countries or regions with weak regulatory frameworks.
Customer Risk: Politically Exposed Persons (PEPs) or companies with complex corporate structures.
Product/Service Risk: Services involving high-value cash transactions, international wire transfers, or digital assets.
Delivery Channel Risk: Non-face-to-face onboarding or interactions hidden behind anonymous third parties.
5. Customer Due Diligence (CDD)
Business transactions will not occur without establishing and verifying client identities.
Standard Due Diligence (CDD): Collection of full legal names, government-issued IDs, dates of birth, and official addresses. For legal entities, we verify the Certificate of Incorporation and identify beneficial owners with ownership.
Enhanced Due Diligence (EDD): Applied to high-risk entities. Requires verification of the source of wealth, more frequent tracking, and formal sign-off from senior management.
Sanctions Screening: All prospective clients are checked against relevant international sanctions lists prior to onboarding.
6. Suspicious Activity Tracking & Reporting
Employees must report any unusual transaction patterns to the MLRO immediately.
Reporting Protocol: Suspicions must be documented via internal report forms detailing the names, dates, values, and reasons for concern.
No "Tipping Off": Employees are strictly prohibited from informing a client that they are under suspicion or being investigated.
7. Record Keeping
All documents collected during verification and tracking are stored securely.
Retention Window: Data must be kept for at least 5 years from the end of the client relationship or transaction date.
Format: Records must create a clear, searchable audit trail for financial regulators or law enforcement.
8. Compliance Audits & Training
Training Program: Mandatory introductory training for all new staff, alongside specialized annual refreshers for departments handling cash or payments.
Internal Reviews: Regular compliance audits are conducted by internal or independent parties to review and update these procedures.
UK-Specific: The UK Government Money Laundering Supervision Guide details your statutory responsibilities.
IM Power plc has a zero-tolerance policy towards money laundering, and is committed to the highest level of openness, integrity, probity and accountability