The purpose of this document is to outline the policies and procedures applied to the provision of mail forwarding services from Third Floor, 207 Regent Street, London, W1B 3HH.
Background
The Chief Money Laundering Officers of Complete Business Services Limited is Leon Williams FCCA. As a qualified Certified Accountant with over 20 years experience in auditing and due diligence work he is well versed in the potential risks of fraudulent behaviour and the means by which persons might attempt to perpetrate these activities.
The Office Manager, Zoe Webber has been trained in the company’s procedures and has been encouraged to apply a rigid approach to the acquisition and verification of documents supplied by those accepted for the service.
Money Laudering Procedures
Provision of Services
All payment for services must be subject to the Royal Bank of Scotland’s verification checks. This includes providing the correct name and address where the credit card is registered to and having knowledge of the invisible password associated with the card required during the “verified by Visa / Mastercard” stage of the payment.
Under no circumstances are cash payments taken.
With experience the staff can become suspicious during a telephone or email enquiry for the services. Requests, for example to collect post rather than have us deliver it often signal that any provision of services carries a high risk.
In such cases staff discourage the persons from signing up.
Length of Service
All services are offered for a period of one year. No monthly, quarterly or 6 monthly facilities are available irrespective of requests for such periods.
Despite the increased sales that would arise from offering shorter time services, having a minimum 12 month period discourages those who might wish to conduct fraudulent activities in the short term and then disappear.
Origin of Applicants
In line with recommended guidance from Royal Bank of Scotland’s anti fraud team applicants from certain high risk countries are not accepted. The current list of countries in this category is: Algeria, Argentina, Belarus, Bulgaria, Indonesia, Lithuania, Macedonia, Nigeria, Philippines, Romania, Russian Federation, Ukraine, Yugoslavia.
Additions are made periodically on the basis on analysis and prediction.
Money Laundering Documents
The requirements for us to obtain money laundering documents are notified to customers at the time of any enquiry so as to discourage any potential applicants who can not produce the material and also to avoid any future misunderstandings.
Following a payment the customer is notified of receipt and asked to produce the stated money laundering documents. It is made clear that the provision of any service is dependant upon their compliance with this request.
Once documents have been received they are checked for clarity and name and address information is cross-referenced to the delivery address provided.
Documents are filed online and are searchable by Company/ Business Name and the individual’s surname.
Further Checks
Complete Formations have subscribed to Companies House Direct company and director checking facilities and Credit safe Money Laundering software. These can be used to obtain detailed information about companies and individuals.
Changes to Delivery Address
Where a customer requests that we send mail to different address (in cases where they have moved or acquire an office) we request an up to date utility bill bearing their name and that address.
Once we are satisfied, the delivery address details are updated on our system.
Sending Post Checks
Before any item of post is despatched to a customer, checks are carried out to ensure sufficient money laundering material is held. Where this is not the case further emails are sent stating that mail has been received and will only be sent on production of the documents originally requested.
The strength of the emails grows until a final cancellation notice is issued.
Summary
The money laundering procedures adopted are constantly evolving based on experience and to use new tools as they become available.
As mail forwarding is not a core part of our business, we can be reasonably selective as to the number and quality of customers we provide the service to.
The integrity of our business address is of foremost importance to us and our customers.
