Statement of Anti-Money Laundering (AML) Policy

1. Introduction

1.1. Blaze Trail Management Limited (the/our “Company”) is committed to the highest standards of anti-money laundering (AML) compliance and is fully dedicated to preventing the use of its operations for money laundering, terrorism financing, and other financial crimes.

1.2. This statement outlines our Company’s commitment to compliance with the relevant legal and regulatory requirements, particularly those laid out under the UK Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and the Terrorism Act 2000.

2. Scope

2.1. This Anti-Money Laundering (AML) policy applies to all employees, directors, consultants, contractors, and business partners of Blaze Trail Management Limited.

2.2. It is the responsibility of all individuals within the organization to ensure that they are familiar with the policy and adhere to its provisions.

3. Commitment to AML Compliance

3.1. Our Company is committed to the following:

  • Compliance with AML Regulations: Adhering to all applicable AML laws and regulations, including but not limited to the UK Money Laundering Regulations and other relevant UK laws.
  • Customer Due Diligence (CDD): Implementing thorough Customer Due Diligence (CDD) procedures to verify the identity of our clients and monitor ongoing business relationships, ensuring we know our customers and their business activities.
  • Risk-Based Approach: Using a risk-based approach to identify and assess the risks of money laundering and terrorism financing, and applying appropriate risk mitigation measures to reduce and control these risks.
  • Suspicious Activity Reporting (SAR): Reporting any suspicious transactions or activity to the relevant authorities, including the UK Financial Intelligence Unit (UKFIU) at the National Crime Agency (NCA).
  • Training and Awareness: Providing regular training and guidance to all employees on AML obligations, red flags to watch for, and their role in preventing money laundering.
  • Record-Keeping: Ensuring that all relevant records related to customer identification, transactions, and AML procedures are maintained in accordance with statutory requirements.
  • Independent Review: Periodically conducting independent reviews and audits of our AML procedures to ensure compliance and address any gaps in our processes.

4. Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD)

4.1. Our Company undertakes appropriate due diligence measures on all customers before establishing a business relationship.

4.2. CDD involves:

  • Verifying the identity of the customer using reliable, independent source documents, data, or information.
  • Understanding the nature of the customer’s business and the intended purpose of the business relationship.
  • Monitoring transactions on an ongoing basis to ensure they are consistent with the customer’s risk profile and nature of the business.

4.3. In cases of higher risk, Company shall apply Enhanced Due Diligence (EDD), which involves obtaining additional information about the customer and increased scrutiny of transactions.

5. Reporting Suspicious Activity

5.1. All employees are required to report any suspicions of money laundering or terrorism financing to the Line Manager without delay.

5.2. The Line Manager shall review all reports and, where necessary, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

5.3. Failure to report suspicious activities can result in criminal liability for the individual employee as well as the Company.

6. Staff Training

6.1. All staff members of our Company shall receive training to ensure they are aware of their responsibilities under the AML regulations.

6.2. This training shall be regularly updated to reflect any changes in the law or the Company’s internal procedures.

7. Penalties for Non-Compliance

7.1. Failure to comply with AML obligations can lead to severe consequences for the Company and its employees, including criminal charges, fines, and reputational damage.

7.2. Company shall take any breach of this policy seriously and may take disciplinary action against employees involved in such breaches.

8. Continuous Improvement

8.1. Our Company is committed to continuously improving its AML framework and procedures by keeping abreast of developments in AML regulations, guidance, and best practices.

8.2. Regular reviews of the effectiveness of Company´s policies are carried out in addition to audits periodically undertaken by Incredible Growth Solutions internal audit function.

8.3. This provides senior executive management oversight committees and the board audit committee with the necessary assurance regarding the operating effectiveness of the group’s controls relating to these policies.

8.4. By implementing these stringent anti-money laundering measures, Blaze Trail Management Limited ensures that its business operations are not misused for criminal purposes and remains compliant with UK regulations.

Reviewed & Approved: November 2024