FINANCIAL CRIME / ANTI MONEY LAUNDERING (AML) STATEMENT

General Statement

The directors of Green Technology Finance Limited trading as GTF Event Equipment Finance (the Firm) are fully aware of the threats to their business, and the broader economy, in relation to the effects of financial crime. They understand that the definition of financial crime does not just cover money laundering.

The Financial Services and Markets Act 2000 (FSMA) defines financial crime as including ‘any offence involving;

a) fraud or dishonesty,
b) misconduct in, or misuse of information relating to, a financial market, or
c) handling the proceeds of crime’.

The Financial Conduct Authority (FCA) defines Financial Crime as ‘fraud or dishonesty, market abuse and handling the proceeds of crime’.

According to the FCA, there are a number of different ways in which someone can be involved in financial crime.

1. A Firm directly suffers from a financial crime if, for example:

  • The Firm is defrauded by an employee (e.g. a company director embezzles corporate funds);
  • The Firm is defrauded by organised criminals.

2. A Firm is exploited as a vehicle for financial crime if, for example:

  • Criminals use the Firm’s services to launder the proceeds of crime,
  • A Firm’s Customer makes payments to terrorists,
  • Customer data held by the Firm is stolen and used to commit identity theft.

3. A Firm, or a representative of the Firm, carries out a financial crime, perhaps in collusion with another party if, for example:

  • A member of staff knowingly overstates the income of a Customer to obtain finance for which the Customer was not otherwise eligible.

Financial crime is therefore considered relevant to the following areas;

  • Anti-money laundering
  • Financial sanctions
  • Data security
  • Fraud and bribery controls

The broad objective of GTF Event Equipment Finance’s anti-financial crime policy is to know who our Customers are, what they do, and whether or not they are likely to be engaged in criminal activity.

It is important to note the Firm does not undertake Anti-Money Laundering checks but it’s officers:

  • Meet with all new Customers and equipment suppliers at their business premises,
  • Collate information on individuals that it passes to it lenders to enable them to perform full
  • Anti-Money laundering checks, and
  • Do not accept cash payments for deposits, advance lease repayments or for any other reason.

Our underlying obligation is that we must be satisfied and can demonstrate that the person we are dealing with is who they claim to be, therefore, evidence of the client’s identity must be obtained and recorded.

Further, although the Firm does not itself conduct Anti-Money Laundering checks, it understands its responsibilities in this respect and always fully cooperates with it’s lenders, their Money Laundering Reporting Officers and all appropriate authorities.

Reporting Suspicious Activity

The Firm applies proportional but appropriate measures to limit the effects of financial crime.

The Firm has ostensibly 2 ‘Customer’ groups.

  • Businesses that have expressed interest in the Firm providing assistance in the form of arranging a lease, hire-purchase or commercial loan agreement for them, and
  • Businesses that supply goods and services to businesses that require a lease, hire-purchase of loan agreement to pay for their goods and services.

If as part of its Customer Due Diligence (CDD) if there is any suspicion of fraudulent activity, the Firm will:

  • Not establish a business relationship or carry out any transaction,
  • Terminate any existing relationship,
  • Inform the lender(s) involved in a potential transaction, and
  • Consider whether to make a suspicious activity report to the Serious Organised Crime Agency (SOCA).

In every instance of suspicious activity, the Managing Director of the Firm will:

  • Complete a full report surrounding all circumstances relating to the suspicious activity,
  • Investigate each instance to determine whether it provides grounds for knowledge or suspicion, and if so, will report the matter to SOCA as soon as practicable,
  • Retain the report as auditable evidence of the work performed to legal and regulatory obligations, and
  • To be available for any investigations.

Document Retention

Customer information –

Steps taken to identify Customers, and copies of, or references to, the evidence of the Customer’s identity (and verification) obtained as part of the CDD process.

Records of ID evidence will be kept for at least five years after a Customer relationship ends. The end date is when the account(s) is closed, or the date of an occasional transaction, or last in a series of linked transactions.

Transactions –

All transactions carried out on behalf of or with a Customer will be recorded. These records will be sufficient to create a satisfactory audit trail if necessary.

Records of all transactions relating to a Customer will be kept for five years from the date on which the transaction is completed.