Financial Crime

ShareIn has a Financial Crime prevention framework which applies to all employees of our company. It aims to maintain the high standards of conduct which currently exist within the company to prevent criminal access to ShareIn’s systems and services to prevent criminals to profit through the proceeds of crime.

The Policy sets out the framework implemented at ShareIn which must be followed to enable the Company to comply with its legal obligations. Further detail can be found below.

8.1 Anti-Money Laundering

Any financial services business that becomes involved with criminal money will suffer severe reputational damage, possible criminal prosecution and will risk losing its authorisation to conduct financial services business. Accordingly, it is essential that all members of staff are and remain aware of the risks of becoming involved in money laundering, and of the procedures ShareIn have adopted to manage this risk.

ShareIn operate within a legal and regulatory structure that places major obligations on our business and us as individuals to assist in the prevention of money laundering. More information can be found in the ShareIn Anti-Money Laundering Policy.

8.2 Suspicious Activity Reporting

You must raise an internal report where you have knowledge or suspicion, or where there are reasonable grounds for having knowledge or suspicion, that another person is engaged in money laundering, or that terrorist property exists.

More information on Suspicious Activity Reporting can be found in the ShareIn Anti-Money Laundering Policy.

8.3 Whistleblowing

ShareIn is committed to high standards of openness, accountability and integrity, and these behaviours are very much part of our organisational culture and values.

In line with that commitment, we recognise that an important aspect of those values is to provide a mechanism to enable suspicions, concerns and matters such as breaches or failures to be raised in a reasonable, effective, and safe manner.

ShareIn has a Whistleblowing Policy which details this further.

8.4 Customer Due Diligence

The Money Laundering Regulations 2017, as well as regulatory guidance, require a risk-based approach to be applied to both verification of identity and further customer due diligence (CDD) activities. Firms need to know who their customers are to guard against fraud, and the risk of committing offences under the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act.

Therefore, we need to carry out customer due diligence and monitoring for two main reasons:

• To help us, at the time due diligence is carried out, to be reasonably satisfied that customers are who they say they are, to know whether they are acting on behalf of another, and that there are no legal barriers (e.g. government sanctions) to providing them with the product or service requested;
• To enable us to assist with law enforcement, by providing available information on customers or activities being investigated.

The ShareIn Anti-Money Laundering Policy details this.