Anti Money Laundering Policy

Last updated: March 2026

1. Introduction

TrustJar is committed to preventing money laundering and terrorist financing in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).

We have implemented strict policies and procedures to ensure that our services are not used to facilitate financial crime. This policy outlines our approach to risk management, client identification, and reporting obligations.

2. How We Manage The Risk

We manage the risk of money laundering and terrorist financing through a comprehensive risk-based approach, which includes:

• Conducting firm-wide risk assessments to identify and assess potential vulnerabilities.

• Implementing robust Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures.

• Providing regular, mandatory training for all staff on AML regulations and red flags.

• Appointing a designated Money Laundering Reporting Officer (MLRO) to oversee compliance.

• Maintaining secure and accurate records of all client identification and transactions.

  
  

3. Identification Process

Before establishing a business relationship or carrying out an occasional transaction, we are required by law to verify the identity of our clients. This process is known as Customer Due Diligence (CDD).

We must identify the beneficial owners of corporate clients, trusts, and other legal arrangements. We may use electronic verification services alongside documentary evidence to confirm identity.

4. Individual Identity Documents

To verify your identity, we require one document from List A (Proof of Identity) and one document from List B (Proof of Address).

List A: Proof of Identity

• Valid Passport

• Valid Photocard Driving Licence

• National Identity Card

• Firearms Certificate or Shotgun Licence

  
  

List B: Proof of Address (Must be dated within the last 3 months)

• Utility Bill (Gas, Electric, Water, Landline)

• Bank or Building Society Statement

• Council Tax Bill (valid for current year)

• Mortgage Statement (valid for current year)

• HMRC Tax Notification

  
  

List C: Entity Specific Requirements

Depending on the nature of the entity, additional documentation is required:

• Probate: Grant of Probate or Letters of Administration, plus ID for all Executors/Administrators.

• Limited Company: Certificate of Incorporation, Memorandum and Articles of Association, and ID for all Directors and shareholders holding more than 25%.

• Offshore Company: Certificate of Incorporation, Certificate of Good Standing, Register of Directors and Members, and ID for ultimate beneficial owners.

• Trusts: Trust Deed, ID for all Trustees, and identification of the Settlor and Beneficiaries.

  
  

5. Suspicious Activity Reporting

Under the Proceeds of Crime Act 2002, we have a legal obligation to report any knowledge or suspicion of money laundering to the National Crime Agency (NCA).

If we submit a Suspicious Activity Report (SAR), we are strictly prohibited from informing the client or any third party that a report has been made (the offence of "tipping off"). We may also be required to suspend transactions or services while awaiting clearance from the NCA.

6. Records Retention

In accordance with AML regulations, we are required to retain copies of all customer due diligence documents and records of transactions for a minimum period of five years after the end of the business relationship or the completion of an occasional transaction.

All records are stored securely and processed in compliance with our Privacy Policy and the UK General Data Protection Regulation (UK GDPR).