Purpose
Mazel Grand HMS is committed to preventing money laundering, terrorist financing, and fraud. This policy explains how we verify who we work with and the measures we take to ensure financial integrity.
As a UK-registered company operating in data processing and IT consultancy, we are subject to UK anti-money-laundering regulations where applicable to our business activities.
Scope
This policy applies to all clients engaging Mazel Grand HMS for data processing, reporting, or consultancy services. It also applies to our own financial operations and internal controls.
Risk-based approach
We apply a risk-based approach to client verification. The level of due diligence we perform is proportionate to the engagement size, payment method, and jurisdiction.
- Standard due diligence: applied to most business clients with clear corporate structures.
- Enhanced due diligence: applied for larger engagements, cross-border payments, or clients from higher-risk jurisdictions.
- Simplified due diligence: applied for low-risk micro-engagements where regulatory risk is minimal.
When KYC applies
Client verification is performed at the following stages:
- Onboarding: all new business clients before the first engagement commences.
- Payment processing: when a client makes their first payment or changes payment methods.
- Changes: when payment patterns change unexpectedly or the client structure changes.
- Periodic review: for ongoing retainer clients, we may re-verify information annually.
- Legal trigger: when required by applicable law or regulatory change.
Information we may request
Depending on the risk level and engagement context, we may request the following information:
- Company details: legal name, registration number, registered address, and country of incorporation.
- Beneficial ownership: names of directors, shareholders with 25%+ ownership, or beneficial owners for corporate clients.
- Contact details: business email, phone number, and website where applicable.
- Source of funds: confirmation that payment funds come from a legitimate business source, where indicators require it.
- Government-issued ID: for individual clients or named representatives, we may request passport or national ID verification.
- Business documentation: incorporation documents, shareholder agreements, or proof of address in certain cases.
Document verification
We verify submitted documents through reasonable means before accepting an engagement.
- Company registration checks against public registries (e.g., Companies House in the UK).
- Document authenticity review: we look for signs of alteration or forgery.
- Cross-referencing: we compare information across multiple sources where possible.
- Electronic verification: we may use third-party verification services for identity or company checks.
Sanctions and PEP screening
We screen clients and associated individuals against sanctions lists and politically exposed person (PEP) databases where applicable.
- Sanctions lists: we check against UK, EU, US, and UN sanctions lists.
- PEP screening: we identify politically exposed persons and apply enhanced due diligence where required.
- Adverse media: we may check for adverse media coverage indicating reputational risk.
- Ongoing monitoring: for retainer clients, we periodically re-screen during the engagement.
Payment controls
Our payment processing is designed to prevent money laundering and fraud:
- Secure payment processing: all card payments are processed through secure payment infrastructure; we do not store card details.
- Bank transfer verification: for bank transfers, we verify the account holder matches the client name.
- Payment monitoring: we monitor for unusual payment patterns, such as large one-off payments or rapid escalation in engagement value.
- No cash payments: we do not accept cash or cryptocurrency payments.
- Invoice-based payments: all payments are linked to a specific engagement with a clear scope and deliverables.
Red flags
We are alert to indicators that may require additional investigation or refusal of engagement:
- Inconsistent or incomplete information provided during onboarding.
- Unusual payment patterns unrelated to business needs.
- Requests to bypass standard verification or documentation requirements.
- Clients from jurisdictions with weak AML controls without clear business rationale.
- Complex corporate structures without clear business justification.
- Reluctance to provide source of funds or beneficial ownership information.
Refusal and termination
We reserve the right to refuse or terminate an engagement in the following circumstances:
- KYC cannot be completed satisfactorily despite reasonable efforts.
- The client is identified on a sanctions list or poses an unacceptable regulatory risk.
- Provided information is found to be false or misleading.
- The client refuses to provide requested documentation.
- Engagement proceeds despite our refusal due to regulatory concerns.
Reporting obligations
If we encounter suspicious activity or have reasonable grounds to suspect money laundering or terrorist financing, we will report through the appropriate legal channels in accordance with UK law.
- We do not tip off clients when a report is made.
- We maintain records of our KYC processes and any reports made.
- We cooperate with law enforcement and regulatory authorities when required.
Data protection and retention
KYC data is treated with the same data protection standards as engagement data:
- KYC documents are stored securely and access is restricted to authorised personnel.
- KYC data is retained for as long as required by law and for the duration of the business relationship.
- After the retention period, KYC data is securely deleted in accordance with our data retention policy.
- KYC data is not used for purposes unrelated to client verification and AML compliance.
Staff training and awareness
All personnel involved in client onboarding and engagement management receive training on:
- Identifying red flags and suspicious activity.
- Understanding our KYC and AML procedures.
- Knowing when to escalate concerns internally.
- Complying with reporting obligations.
Policy review
This policy is reviewed annually or when regulatory requirements change. Updates are communicated to relevant staff and reflected in our client onboarding process.
Contact
Questions about this policy or our KYC procedures: info@mazelgrandhms.com.
If you wish to report concerns about financial crime in our operations, use the Speak-Up Policy for confidential reporting.