Lynam & Co: Anti-Money Laundering (AML) Policy
Effective Date: 25 April 2025
Review Date: 25 April 2026
1. Policy Statement
Lynam & Co is committed to the highest standards of ethical conduct and integrity in its business activities. We comply fully with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs), the Proceeds of Crime Act 2002 (POCA), the Terrorism Act 2000, and all relevant guidance issued by the AAT, our supervisory authority for AML purposes.
This policy sets out our risk-based approach to preventing and detecting money laundering and terrorist financing.
2. Scope
This policy applies to all partners, employees, subcontractors, and anyone acting on behalf of Lynam & Co.
3. Money Laundering Reporting Officer (MLRO)
The appointed MLRO for Lynam & Co is:
Name: Bradley Lynam
Position: Principal
Email: bradley@lynamandco.com
The MLRO is responsible for:
- Receiving and evaluating internal suspicious activity reports (SARs);
- Making external SARs to the National Crime Agency (NCA);
- Keeping AML records and documentation;
- Ensuring staff awareness and training.
4. Customer Due Diligence (CDD)
We conduct risk-based CDD before establishing a business relationship or carrying out occasional transactions.
4.1 Standard CDD
We obtain:
- Full name and date of birth (for individuals)
- Address
- Company information (if applicable)
- Proof of identity (passport/driving licence)
- Proof of address (utility bill, bank statement – dated within 3 months)
4.2 Enhanced Due Diligence (EDD)
EDD is applied in higher-risk situations, including:
- Politically Exposed Persons (PEPs)
- Non-face-to-face onboarding
- High-risk jurisdictions
- Complex or unusually large transactions
EDD may include:
- Verifying source of funds/wealth
- Additional documentation
- Independent verification via reliable third parties
4.3 Ongoing Monitoring
We monitor all client relationships on a regular basis. This includes:
- Reviewing client activity for inconsistencies
- Updating records annually or upon material changes
- Triggering re-verification where appropriate
5. Risk Assessment
We adopt a firm-wide risk-based approach, assessing the following risks:
- Client Risk: Sector, location, structure
- Service Risk: Type and complexity of services
- Geographic Risk: Country of client’s operations
- Delivery Channel Risk: Remote onboarding, etc.
We document and update our Practice-Wide Risk Assessment (PWRA) annually.
Each client also undergoes an Individual Risk Assessment, recorded in our files.
6. Suspicious Activity Reporting
All employees must report knowledge or suspicion of money laundering or terrorist financing to the MLRO immediately using an internal report form. The MLRO will assess and, if necessary, submit a SAR to the NCA.
It is an offence to:
- Tip off a client;
- Prejudice an investigation;
- Fail to report a suspicion.
7. Record Keeping
We maintain the following for at least 5 years:
- CDD documents
- Risk assessments
- Internal SARs
- Communications relating to AML compliance
Records are kept securely in line with the Data Protection Act 2018 and GDPR.
8. Training
All relevant staff must undergo AML training:
- At induction
- Annually thereafter
- When regulations or internal procedures change
Training is documented and tailored to roles and responsibilities.
9. Internal Controls and Review
We implement proportionate internal controls, including:
- Segregation of duties (where applicable)
- Use of secure systems for client onboarding and communication
- Regular file reviews and spot checks
This policy is reviewed annually or in response to regulatory changes.
10. Compliance Declaration
Lynam & Co confirms that:
- It is registered with the AAT as its AML supervisory body;
- It maintains an up-to-date AML policy and firm-wide risk assessment;
- It has appropriate CDD, record-keeping, and reporting procedures in place.
11. Bribery and Corruption
Lynam & Co adopts a zero-tolerance approach to bribery and corruption, in line with the Bribery Act 2010. While this legislation is distinct from anti-money laundering regulations, any suspicions of bribery or facilitation payments will be reported to the MLRO and, where appropriate, to the relevant authorities.
A separate Anti-Bribery Policy is available and is reviewed annually alongside this AML policy.
Signed:
Bradley Lynam AATQB
Sole Practitioner, Lynam & Co
Date: 25 April 2025