MLRO /Head of Compliance Department Fatima Fernandes

ANTI-MONEY LAUNDERING
MANUAL

CONTENTS

Page 1. Glossary of terms.3 2. Introduction....8 3. Policy statement9 4. Compliance management structure...9 5. Risk assessment......14 6. The Law.....26 7. CDD....37 8. SAR.46 9. Record Keeping.51 10. Policies and Procedures Annex I ................................................52

11. Forms Annex II.............................................................................75

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GLOSSARY OF TERMS AFU Asset Freezing Unit which is a department within HM Treasury responsible for the freezing of assets belonging to sanctioned individuals. AML Beneficial Owner Anti-Money Laundering The individual who ultimately owns or controls the customer or on whose behalf a transaction or activity is being conducted. Business Relationship A business, professional or commercial relationship between a relevant person (i.e. someone to whom the MLR 2007 apply) and a customer, which is expected by the relevant person, at the time when the contact is established, to have an element of duration. Cash Consent Notes, coins and travellers cheques in any currency. Permission given by SOCA, for the carrying out of any action that would constitute a money laundering offence in the absence of that permission (see section 10). Criminal Conduct Conduct which constitutes an offence in any part of the United Kingdom, or would constitute an offence in any part of the United Kingdom if it occurred there. Criminal Property Any money or other assets which constitutes a persons benefit from crime. Customer due diligence (CDD) Identifying and verifying the identity of the customer and any beneficial owner of the customer, and obtaining information on the purpose of intended nature of the business relationship. EEA Enhanced due diligence European Economic Area Additional customer due diligence measure that must be applied: Where the customer has not been physically present for identification purposes. Where the customer is a Politically Exposed Person or In any other situation which by its nature can present a higher risk of money laundering or terrorist financing.

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FATF Financial Sanctions Target List

Financial Action Task Force. A consolidated list of targets listed by the United Nations, European Union and United Kingdom under legislation relating to current financial sanctions regimes. It is maintained by the AFU.

FSA

Financial Services Authority: statutory regulator of most financial services providers under the Financial Services and Markets Act 2000.

HMRC

Her Majestys Revenue and Customs. Supervisory authority for all MSB.

Identification

Ascertaining the name of, and other relevant information about, a customer or beneficial owner.

Internal Report

A report made to the Nominated Officer or MLRO in a business.

JMLSG

Joint

Money

Laundering

Steering

Group:

body

representing UK Trade Associations in the Financial Services Industry and aiming to promote good antimoney laundering practices and give relevant practical guidance. Money Laundering An act which: Constitutes an offence under s. 327, 328 or 329 of POCA or Constitutes an attempt, conspiracy or indictment to commit such an offence or Constitutes aiding, abetting, counselling or procuring the commission of such an offence or Would constitute an offence specified above if done in the United Kingdom. [POCA, s. 340 (11)] A person also commits an offence of money laundering if he enters into or becomes concerned in an arrangement which facilitates the retention or control by or on behalf of another person of terrorist property: By concealment By removal from the jurisdiction By transfer to nominees or In any other way.

[Terrorism Act, s. 18]

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MLR 2007 MLRO

The Money Laundering Regulations 2007 Money Laundering Reporting Officer. This term is used to describe the nominated officer appointed under regulations 20 (2) (d), MLR 2007 and s331, POCA.

Money Service Business

An undertaking which by way of business operates a currency exchange office, transmits money (or any representations of monetary value) by any means or which cashes cheques which are made payable to customers.

Nominated Officer

A person in a firm or organisation nominated by the firm or organisation to receive disclosures under Regulation 7 and s. 330 of POCA from others within the firm or organisation who know or suspect that a person is engaged in money laundering. Similar provisions apply under the Terrorism Act.

Occasional transaction

A transaction (carried out other than as part of a business relationship) amounting to 15,000 euro or more, whether the transaction is carried out in a single operation or several operations that appear to be linked.

Ongoing monitoring of a business relationship

Scrutiny of transactions undertaken throughout the course of the relationship (including, where necessary, the source of funds) to ensure that the transactions are consistent with the relevant persons knowledge of the customer, his

business and risk profile and Keeping the documents, data or information obtained for the purpose of applying customer due diligence measures up to date. OFAC US Treasury Office of Foreign Assets Control.

Administers and enforces economic and trade sanctions based on US foreign policy and national security goals against targeted foreign countries, terrorists and

international drug traffickers. OFAC SDN List Collectively, individuals and companies that are

designated by OFAC are called "Specially Designated Nationals" or "SDNs." OFAC publishes a SDN list. POCA Proceeds of Crime Act 2002.
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Politically Exposed Person (PEP)

An individual who is or has, at any time in the preceding year, been entrusted with prominent public functions, or an immediate family member of such an individual, or a known close associate, of such persons.

Prejudicing an Investigation

The making of any disclosure or falsifying, concealing, or destroying, or being complicit in these, of any documents that are relevant to a money laundering investigation.

Regulated Sector

Persons and firms which are subject to Money Laundering Regulations.

Regulation EC 1781/2006

European Union Wire Transfer Regulations. Obliges payment service providers to send information on the payer with every transfer made on their behalf.

SAR Senior Management

Suspicious activity report made to SOCA. The directors and senior managers (or equivalent), of a firm who are responsible, either individually or

collectively, for management and supervision of the firms business. Senior Manager An individual, other than a director (or equivalent), who is employed by the firm, and to whom the board (or equivalent) or a member of the board, has given responsibility, either alone or jointly with others, for management and supervision. Simplified due diligence An exception to the obligation to apply the customer due diligence measures for specified customers, e.g. financial institutions subject to the Money Laundering Directive or equivalent legislation and supervision. It is also available for some categories of products and transactions which may be provided by financial institutions. SOCA Supervisory Authority Serious Organised Crime Agency Bodies identified by MLR 2007 regulation 23 as being empowered to supervise the compliance of relevant businesses with the 2007 Regulations. Terrorism Act (TA 2000) Terrorism Act 2000, as amended by the Anti-terrorism, Crime and Security Act 2001. Terrorist offences The terrorist offences relate to fundraising, using or possessing terrorist funds, entering into funding

arrangements, money laundering, disclosing information

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relating to the commission of an offence (similar to tipping off), or failing to make a disclosure in the regulated sector. (ss 19 and 21A TA 2000 (as amended)). Terrorist Property Money or other property which is likely to be used for the purposes of terrorism (including any resources of a prescribed organisation) or Proceeds of the commission of acts of terrorism or Proceeds of acts carried out for the purposes of terrorism.

Proceeds of an act includes a reference to any property which wholly or partly, and directly or indirectly, represents the proceeds of the act (including payments or other rewards in connection with its commission).

Resources includes any money or other property which is applied or made available, or is to be applied or made available, for use by the organisation. [Terrorism Act, s. 14] Tipping off A tipping-off offence is committed if a person knows or suspects that a disclosure falling under POCA s 337 or 338 has been made, and he makes a disclosure which is likely to prejudice any investigation which may be conducted following the disclosure under s 337 or s 338. [POCA, s 333A]. Transaction The provision of any advice by a business or individual to a client by way of business, or the handling of the clients finances by way of business. A transaction could be simply operating across a clients account. Verification Verifying the identity of a customer, by reference to reliable, independent source documents, data or information, or of a beneficial owner through carrying out risk-based and adequate measures.

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INTRODUCTION This manual is designed to be used by the employees of LCC TRANS SENDING LIMITED, a company that belongs to the Small World Group, as a guide to the AML responsibilities of both the company and the staff.

In particular, it contains the information which all members of staff need to be aware of in order to prevent the business being used to launder the proceeds of crime or terrorist financing. All members of staff are at risk of committing a criminal offence if they assist in a criminal transaction by missing the warning signs.

At the heart of this document is the risk based approach (see below). The risk-based approach means that we focus our resources on the areas of greatest risk.

The possibility of being used to assist with money laundering and terrorist financing poses many risks for our company including:

1. criminal and disciplinary sanctions 2. civil action against the firm as a whole and individual directors 3. damage to reputation leading to a loss of business

These risks must be identified, assessed and mitigated. If we know our customers well and understand their instructions thoroughly, we will be better placed to assess risks and spot suspicious activities. We will always start from the premise that most of our customers are not launderers or terrorist financers but we must assess the risk level particular to our firm and implement reasonable and considered controls to minimise those risks.

No matter how thorough our risk assessment or how appropriate our controls, some criminals may still succeed in exploiting us for criminal purposes. But an effective, risk-based approach and documented, risk-based judgments on individual customers will enable us to justify our position on managing the risk to law enforcement, courts, HMRC and FSA.

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POLICY STATEMENT

The Directors are committed to operating the business in a transparent and open manner consistent with their regulatory obligations. The directors and MLRO will always ensure that all suspicious activity is reported to the authorities.

As part of this commitment LCC TRANS SENDING LTD will adopt strict compliance of all applicable AML rules and regulations with specific emphasis on POCA, the 2007MLR and EU Payment Services Directive 2009.

LCC TRANS SENDING LTD is aware that MSB have in the past been targets of organised crime seeking to launder the proceeds of illicit activity. LCC TRANS SENDING LTD will always seek to disrupt this activity by cooperating fully with the authorities and reporting all suspicious activity to SOCA.

All staff must take steps to ensure compliance with this policy and ensure that they fully understand the material contained in this manual.

It is the policy of LCC TRANS SENDING LTD that staff must receive AML training on commencement of their duties. Staff will be given a copy of this manual and will be tested on its contents before starting any client facing duties. The MLRO holds copies of all training materials. Updated AML training is given annually. Records of all training including dates delivered and by whom are kept both centrally and on staff personnel files.

The MLRO of LCC TRANS SENDING LTD is Fatima Fernandes. Her deputy is Seanna Manita. All issues relating to SAR must be referred to Fatima in the first instance. The compliance director of LCC TRANS SENDING LTD is Nicholas Day.

A copy of this manual will be provided to all LCCs subsidiaries, EEA Branches and all directors, staff and agents.

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ROLES AND RESPONSABILITIES

Senior Management

Responsible for overall compliance policy of LCC TRANS SENDING LTD and ensuring adequate resources are provided for the proper training of staff and the implementing of risk systems. This includes computer software to assist in oversight. Senior management will be sent monthly updates by the MLRO on compliance. They will also receive and consider the annual MLRO report and implement any recommendations made within it. Assistance may be given to the MLRO in the preparation of the AML manual.

MLRO

Responsible for receiving internal disclosures and making reports to SOCA. First point of contact for all compliance issues from staff. Prepares annual report for consideration of senior management and conducts risk assessments of compliance systems. Undertakes regular random analysis of transactions including assessment of documentary evidence provided by customers. Visits agents and overseas branches to ensure compliance with group strategy. Assists in making any necessary amendments to AML manual in line with increase/decrease in risk. Considers all compliance issues for group undertakings including daily consideration of compliance forms.

Staff

Responsible for considering the AML manual and understanding responsibilities. Ensure company procedures adhered to and obtain all documentary evidence as outlined within manual. Ensure that all suspicious circumstances are reported to MLRO. LCC TRANS SENDING LTD BUSINESS PROFILE

LCC TRANS SENDING LTD is an authorise Payment Institution licensed by FSA (Financial Service Authority) FRN 504482, and currently we have EEA Branches in Belgium; Netherlands, Luxembourg, Germany, Ireland, Italy, Portugal and France We provide in the UK money transfer, bureau of change and cheque cashing facilities to all members of the public.

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LCC Trans Sending is authorised to provide payment services of money remittance under PSD Outward Service to Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Gibraltar, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovak Republic, Slovenia, Spain and Sweden. ANTI MONEY LAUNDERING SYSTEMS AND CONTROLS Under the MLR 2007 we are required to establish appropriate risk-sensitive policies and procedures in order to prevent activities related to money laundering and terrorist financing including those policies and procedures, which provide for:

Identification and scrutiny of complex or unusually large transactions, unusual patterns of transactions with no apparent economic or lawful purpose and other activities regarded by the regulated person as likely to be of the nature of money laundering or terrorist financing;

Prevention of use of products favouring anonymity;

Determination of whether a client is a PEP, using the Bridger Insight Platform

which screens all customers and beneficiaries names against PEPs databases worldwide;
Customer due diligence i.e. procedures designed to acquire knowledge about our customers and to verify their identity, as well as monitor business relationships and transactions before executing the remittances;

Internal reporting including the appointment of a MLRO to receive the money laundering reports required under POCA and the TA 2000 and a system for making those reports;

Record keeping, including details of customer due diligence and supporting evidence for business relationships, which need to be kept for five years after the end of a relationship and records of transactions, which also need to be kept for five years;

Internal control, risk assessment and management, compliance monitoring, management and communication; and

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In addition, we are required to take measures to make employees aware of the law relating to money laundering and terrorist finance, and to train those employees in how to recognise and deal with transactions which may be related to money laundering or terrorist financing.

THE RISK BASED APPROACH

A risk based approach allows us to target resources and effort where the risk is greatest and, conversely, reduce requirements where the risk is low.

We must establish adequate and appropriate policies and procedures relating to risk assessment and management in order to prevent operations related to money laundering or terrorist financing. We have done this by preparing a risk matrix to be adopted by all staff.

We must :

(a) determine the extent of customer due diligence measures (section 5) on a risksensitive basis depending on the type of client, business relationship, or services to be provided;

(b) be able to demonstrate to HMRC and FSA that the extent of customer due diligence measures is appropriate in view of the risks of money laundering and terrorist financing. Our CDD measures are set out in this manual.

We are required to take a risk-based approach and have adequate measures to verify the identity of beneficial owners so that we are satisfied that we know who the beneficial owner of our customer is and what the control structure of a corporate client is. Every personal customer is asked about any beneficial owners on compliance form E. Corporate customers undergo thorough beneficial ownership assessment in line with our obligations under the MLR 2007.

We are required to scrutinise transactions and other activities throughout the course of any business relationship to ensure consistency with our knowledge of our customers, their business and risk profile. The MLRO will conduct ongoing monitoring of all high risk accounts including customers who regularly transfer more
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than 900 per month. In addition to this the MLRO will undertake random monthly checks upon customer accounts and provide a report to the compliance director on her findings.

We must also keep up to date the information collected in applying CDD measures. All ID will be retaken on the expiry of any documents used to verify customers. Customer accounts will be placed on hold until the relevant CDD checks have been undertaken or documents provided.

We must apply CDD measures at appropriate times to existing clients on a risksensitive basis. The MLRO will assess the existing CDD database to identify those customers that may require further/updated CDD checks.

We must apply EDD where the customer is another PI or SPI and ongoing and monitoring transactions are applied. The MLRO will visit the MSB to ensure that they are carrying out CDD and checking the relevant records for specific transactions.

In compliance with the Data Protection Act, when the customer is another MSB we do not request full information from their customer, just the full name of the

customer, amount, recipient name and country and the unique reference number of each transaction. However the PI or SPI must be prepared to disclose any information if required by us. In addition to this, for transactions more than 10.000.00, the proof of source of funds from the MSBs customer is required. Also we conduct due diligences on the MSB before starting a relationship with them to certify that the MSB carries out appropriate Customer Due Diligence. Where the customer is a money transmission business we check if they are registered with the Financial Services Authority (FSA) and HMRC. If they are not registered we will not accept the customer.

We must apply EDD on third party payments. LCC only accepts Third Party Payments for Countries that are not considered high risk jurisdictions by FATF and OFAC and when the beneficial owner is identified.

We apply EDD on the overseas recipient requesting the proof of payment such as invoices and checking if they are genuine.

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When the customer is a corporate customer, we apply EDD before starting the relationship with the customer. We will check the companys and Directors names on sanctioned lists, Safe Credit website, directors disqualified list, the purpose to send the transaction, the annual turnover, the list of customers beneficiaries and the relationship with the them, beneficiaries names on FATF/OFAC lists and other sanctioned lists. We will also define limits of amounts a corporate customer can send in a given period.

When an overseas customer wants to carry out a transfer of funds to a beneficiary in the UK, we treat him as a UK customer and must be identified by our subsidiaries or correspondents while the beneficiary will be identified in the destination country. The very same procedures of identification from LCC will apply.

We provide payment services to agents subject to prior acceptance by us. To comply with FSA requirement, we must obtain from the agent: name and address of the agent, description of AML Internal controls mechanism (must meet the LCC procedure), identification of directors and responsible persons, and fit and proper test assessment. New agents will only start operating after the authorisation from FSA is granted.

We have established internal procedures for investigating any complaint that may be made against us in relation to any transaction. In accordance with our complaints procedure, any complaint a customer may make relating to any transaction must be made or confirmed to us in writing to Head of Client Services at LCC Trans-Sending Ltd,168-170 Bermondsey Street, London SE1 3TQ or by electronic message to customerservice.uk@smallworldfs.com. We will respond to the customer promptly. If the customer is still dissatisfied following our response to any complaint, he has a right to refer the complaint concerning the transaction to the Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR.

In compliance with the communication dated 12 October 2009 from HM Treasury on the Counter Terrorism Act 2008 (CTA), the company will not accept any business relationship with (a) Islamic Republic of Iran Shipping Lines (IRISL) and (b) Bank Mellat. The Company has checked all existing
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transactions to ensure no trading has been done with these concerns. We have additionally blocked Bank Mellat and all their branches regardless the location. Our business development department is aware of these measures. In compliance with the communication daed 11 November 2011 from HM Treasury, the company will not accept any business relationship and transactions with all Iranian Banks, including their branches and subsidiaries and the central bank of Iran.

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Local Compliance Structure LCC Trans-Sending Ltd.

SENIOR MANAGEMENT
Mr. Nicholas Day - Compliance Director Mr. Christiano Simoes Business Development Director Mr Rick Knox Commercial Director

Equally liable for enforcement action

Lcc TransSending Ltd.

Supervisor Can take enforcement action

Regulators HMRC&FSA
Share information

Duty to ensure agherence to AML procedures

Duty to provide AML training and material

COMPLIANCE TEAM
Lcc Trans Sending Ltd MLRO Fatima Fernandes
Give Consent Full Co-operation

EEA Branches nominate officers

UK Fatima Fernandes Ireland Mohammed Rahman Belgium Sofia Freitas Portugal Paulo Sampaio Marques

Italy Luigi Del Principe Germany Daniel Kopelman Luxembourg - Fatima Fernandes Netherlands- Fatima Fernandes France Fatima Fernandes Subsidiaries: MLRO UNO - Spain Javier Perez SwissTransfers Switzerland - Christiano Simoes Choice Money Transfer USA Juan Gomez SW Compliance team: 12 employees

Make Reports

FIU

Report any suspicion

Provide Training to Staff

STAFF

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OUR MONEY LAUNDERING RISKS AND WHAT WE WILL DO TO REDUCE THEM

Risk Customers

Explanation It is important to have a general understanding of the risk profile of our customers based on the type of customers, purpose of transactions, source and destination of funds and the expected value of frequency of transactions. This will enable the identification of unusual transactions or patterns of transactions without an obviously economic or lawful purpose, which could be suspicious.

Triggers New customers that send less than 900 per calendar month,

Mitigating these risks We will request the senders full name, date of birth, nationality, full address, purpose of transaction,

Non face-to-face and customers who are not local to the business that carry out transactions larger than 900

relationship with the beneficiary.

We will undertake Enhanced Due Diligence for all customers who fit the profile identified within the trigger

New customers undertaking large transactions.

section.

Additionally they will have monitoring Customers carrying out regular large transactions. of their account by the compliance department on daily basis, before proceeding with the remittance. Customers undertaking a number of transactions below the amount requiring ID in a short period of time. We will verify the customers identity with reference to the documents referred to in the acceptable ID A number of customers sending section of this manual for customers

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payments to the same individual.

who send more than 900 in a calendar month. In addition to this a

Other SPI or PI s Customers

check will be made against all sanctions lists, PEP databases, Safe

Customers with complex ownership structures with the potential to

Credit, and in some cases the information provided checked

conceal source of funds or underlying electronically. If our PEP database beneficiaries. search produces a match, EDD will be undertaken and no account will Third Party Payments be opened or transaction proceed without the express authority of the Customers who are not local to the business. directors. Any account will be

monitored as detailed above.

All ID will be retaken after the date PEPs of expiry on any document shown. This information will be stored on the Corporate Customers customer file electronically and the MLRO will be prompted when it should be obtained again.

Source

of

funds

enquiries

for

business relationships and higher

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risk transactions will be sought. For individuals that send more than 9,000, this includes completing a Compliance Form (attached) which will be uploaded to the operational system to be verified by the

compliance team.

All customers who send more than 5,000 per month are asked to provide a proof of address.

All customers who send more than 12,500 cumulative in a year are asked to provide a proof of

occupation.

All customers will be asked for their profession. EDD will be undertaken if they work in a profession deemed to be high risk such as a Lawyer, an Accountant, an Estate agent or if they work in/operate a casino or if

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they are identified as a PEP.

When the customer is another PI or SPI, the beneficial name owner is

identified;

and

unique

reference number are requested, including the number of underlying transactions conducted by the other PI or SPI.

On Third Party Payments, EDD is applied on the overseas payment institution. If payment is made against an invoice, evidence of invoice must be provided and the information will be checked. Product/transaction types Overseas remittances/money transfer Overseas remittances can be used by criminals and terrorists to move criminal cash outside of the Unusual patterns of transactions Complex or unusually large transactions. We have put in place robust systems to identify unusual transactions or patterns of transactions. Each client is set a limit of how much they may

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conventional banking system in order to reduce the likelihood of detection.

which have no apparent economic or visibly lawful purpose.

send being

without

further Our

information computer

required.

system is designed to warn staff A sudden increase in business from an existing customer that is not consistent with known sources of income. when a limit is reached or about to be reached. The system will not allow further transactions to proceed without information being inputted as appropriate or on the authority of the Peaks of activity at particular locations or at particular times. Staff should also consider whether Large numbers of transactions slightly below the limit for verification of ID. suspicious circumstances exist and refer to the reporting procedures within the manual if necessary. MLRO or a director.

Channel Cash transactions Money transmission is inherently high risk due to the fact that it deals in the movement of money, often cash, across international borders. Cash funding and cash pay-outs. High value cash remittances. All cash/money exchange transactions over 10,000 require the MLRO to be notified and without proof of source of funds the transaction can not be proceed without the compliance team authorisation. The operational system will enable the staff to input

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the evidence received and that they have informed the MLRO. Cheques are not acceptable for remittance. Cheque Encashment Most common risk to cheque cashers is that of deception by the customer. Third party cheque cashers are not normally exposed to large scale money laundering because the flow of cash goes in the opposite direction to that normally seen. Evidence of tampering on a cheque. Sudden increase in cheque value. Multiple cheques in different names. Company cheques will be registered and all customers for cheque encashment must provide ID, address and a payslip. For all cheques over 2.500 other documentary evidence showing proof of entitlement will be required., in addition on pre approval from MLRO and Barclays bank.

Bureaux de Change

Bureaux de Change can be attractive to money launderers where large sums of money can be exchange into small denominations of a foreign currency

Several customers exchanging small amounts to avoid identification

For all currency exchanges over euro 5.000, customers will be identified with picture ID. For all

currency exchanges over Euros 10,000 other documentary evidence showing proof of source will be required and details of their address. For all Euro 500.00 notes, the

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customer must be identified with picture Id and the serial number note is reported to MLRO. Staff are advised to report to MLRO suspicious our several transaction on Euros 500,00 notes or Euros 200.00 notes.

Dollar transactions

Where we send or convert monies in dollars our regulatory risk increases as we are obliged to consider US regulations.

All dollar transactions

All dollar transactions are automatically screened against the OFAC database.

Use of agents

Agency relationship; where we are dependent on an agent for customer contact this can create a risk of regulatory noncompliance and weaknesses that could be exploited by criminals or terrorists.

Little communication exists between the money transmission business and the agents.

We will always ensure agents undergo fit and proper type scrutiny.

We will ensure agents and their employees are trained in anti-money laundering procedures, including

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how to recognise high risk and suspicious activity and make reports to the Nominated Officer/MLRO. We will monitor agents compliance with ID verification and internal reporting procedures. This will be conducted by the MLRO or her deputies, auditing agents at least once a year and providing an assessment of their compliance to the directors.

We will monitor Agents transactions on daily basis. All agents will get FSA authorisation before starting business with us, and will register at HMRC the first month of starting to trade

Geography

The countries in which we operate and to which we send monies to may give rise to a higher risk of money

Source or destination of funds from or to areas of high level of drugs crime, terrorist activity etc.

We will always keep up to date with news on money laundering or terrorist financing cases via SOCA, FATF, UKMTA, Corruption Index,

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laundering because of a generally higher crime rate or likelihood of money laundering or terrorist financing.

Lack of knowledge regarding origin or destination of funds.

HM Treasury high-risk situations to the regulated sector, our own legal advisor or press reports. All cases will be screened against the HM Treasury sanctions list. We subscribe to alerts from the AFU. We also screen all dollar payments against the OFAC SDN list as noted above. In appropriate cases we may refuse a transaction based upon the particular location the money is requested to be sent to or Enhance Due Diligence.

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The Law

Under the 2007 MLR, the company is obliged to provide all members of staff training on the law relating to money laundering/counter terrorist financing. In line with that obligation we set out below a summary of the legislation and the main issues that you need to be aware of. The applicable legislation is set out in full. Please ensure that you read the legislation so that you are aware of the potential criminal offences and the penalties. Where appropriate, HMRC guidance on the legislation is included to avoid confusion. Staff will be tested on their knowledge of the law as we are obliged to ensure that you are aware of it.

Money laundering is generally defined as the process by which the proceeds of crime, and the true ownership of those proceeds, are changed so that the proceeds appear to come from a legitimate source.

Money laundering can arise from small profits and savings from relatively minor crimes, such as regulatory breaches, minor tax evasion or benefit fraud. A deliberate attempt to obscure the ownership of illegitimate funds is not necessary.

There are three acknowledged phases to money laundering: placement, layering and integration.

Placement

Cash generated from crime is placed in the financial system. This is the point when proceeds of crime are most apparent and at risk of detection.

Layering

Once proceeds of crime are in the financial system, layering obscures their origins by passing the money through complex transactions. These often involve different entities like companies and trusts and can take place in multiple jurisdictions.

Integration

Once the origin of the funds has been obscured, the criminal is able to make the funds reappear as legitimate funds or assets.

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Proceeds of Crime Act 2002 (POCA)

POCA, as amended, establishes a number of money laundering offences including:

1. principal money laundering offences; 2. offences of failing to report suspected money laundering; 3. offences of tipping off about a money laundering disclosure; 4. tipping off about a money laundering investigation; and 5. prejudicing money laundering investigations.

POCA applies to all members of LCC TRANS SENDING LTD staff as our business is in the regulated sector and so all the offences outlined above are applicable to you.

Sections 327 to 329: concealing, arranging, acquiring

These offences apply to all staff. Section 327 it is an offence to conceal, disguise, convert, transfer or remove (from the UK) criminal property

Section 328 it is an offence to become concerned in an arrangement which a person knows or suspects facilitates the acquisition, retention, use or control of criminal property

Section 329 it is an offence to acquire, use or have possession of criminal property

These are the main money laundering offences and where we refer to Money Laundering in this section, what is mean is the attempt, conspiracy to or commission of these offences.

"Criminal property" is property which:

is or represents a person's benefit from criminal conduct; and the alleged offender knows or suspects constitutes or represents such a benefit .

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"Criminal conduct" is conducting which:

is an offence in any part of the UK; or is an offence in the jurisdiction where the conduct took place or where the conduct took place outside the jurisdiction, but would have if it occurred in the UK, attracted a maximum penalty of over 12 months imprisonment

These offences apply to the proceeds of all crimes and to any type of criminal conduct, regardless of amount. Penalty

These offences are punishable upon conviction by a maximum of 14 years imprisonment. The defences

You did not know or suspect that the money or property in question was criminal property. Deliberately shutting your eyes to an obviously suspect situation, will not constitute a defence

You made an authorised disclosure i.e.:

a disclosure to a constable (the police), customs officer or a nominated officer (i.e. using the firms internal reporting procedure) ; and

made in the form and manner prescribed in the regulations;

The companys nominated officer is our Money Laundering Reporting Officer, Fatima Maria Oliveira Fernandes or, in her absence, her deputy, Seanna Manita. Thus members of staff will have a defence by making a disclosure in accordance with the companys internal reporting procedures which are set out below, the effect of which is to report to our MLRO.

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Authorised disclosures can be made either before or after a "prohibited act" occurs, i.e. before the completion of any transaction which amounts to a money laundering offence. External disclosures, by the MLRO, are made to the Serious Organised Crime Agency (SOCA).

Pre transaction disclosures. Where a suspicion has arisen before a "prohibited act" occurs, it will be necessary to receive the appropriate consent before completing any transaction which would amount to a prohibited act. If the prohibited act takes place without this consent, than the disclosure defence will not apply. Appropriate consent must be given by the person who received the authorised disclosure, in this case the MLRO. However, the MLRO cannot give consent until a report has been made to the SOCA and SOCA has given actual or presumed consent (see below). It is an offence for the MLRO to give consent when they should not have done. Time limits for disclosure -- section 335 lays down time limits relating to the delay between the authorised disclosure being made and the appropriate consent being given or presumed.

If the person making the disclosure either receives appropriate consent or hears nothing within seven working days, the transaction can proceed and the disclosure defence will be available. The seven day period is known as the "notice period";

If consent is refused within the notice period the transaction cannot safely proceed unless consent has been given within the "moratorium period" or the "moratorium period" has expired. The moratorium period starts when the appropriate consent is refused and lasts 31 days

Post transaction disclosure is a disclosure which is made after the "prohibited act has occurred. In this case appropriate consent will not be required but the disclosure defence will only apply if a person had a reasonable excuse not to report beforehand. Adequate consideration defence -- there is a defence to section 329, that a person has been paid a proper amount for providing goods and services. However this defence does not apply if the person knew or suspected that the goods or services

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they were providing, and being paid for, might help another to carry out criminal conduct.

Sections 330 failure to disclose: regulated sector

The s330 offence in the Act has been amended by SOCA in a number of key respects:

The offence applies when a person: knows or suspects, or has reasonable grounds for knowing or suspecting that another person is engaged in money laundering. can identify the money launderer or the whereabouts of the laundered property or that he believes that the information he has may assist in identifying the other person or the whereabouts of any of the laundered property

The disclosure must be made as soon as is practicable and must have been made in the course of business. The disclosure must be made to the MLRO or to SOCA.

This offence introduces an objective test for knowledge or suspicion. This means that a person may be guilty of this offence if there were reasonable grounds for knowledge or suspicion i.e. they should have known or suspected. Penalty - punishable on conviction by a maximum of five years imprisonment.

Defences to failure to disclose: regulated sector

Employees in the regulated sector who have not received training about money laundering from their employer may have a defence. However this defence is only available if the employee did not have actual knowledge or suspicion. circumstances there would be ramifications for the employer. In these

It could also be a defence if the person has a "reasonable excuse" for not disclosing the information.

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Section 333A (1) and (3) tipping off

S333A(1) disclosing a suspicious activity report (SAR). It is an offence for a person to make a disclosure which is likely to prejudice an investigation, when the person knows or suspects that an authorised disclosure has been made.

S333A(3) disclosing an investigation. It is an offence to disclose that an investigation into a money laundering offence is being contemplated or carried out if that disclosure is likely to prejudice that investigation. The key point is that you can commit this offence, even where you are unaware that a SAR was submitted.

The disclosure in this context means any form of communication to anyone, not just our own customer.

It is a defence if the person did not know or suspect that the disclosure was likely to prejudice an investigation. S333B Disclosures within an undertaking or group etc It is not an offence if an employee of a firm discloses that a SAR has been made if it is to an employee of the same business.

Any concerns with regard to tipping off should be referred to the MLRO.

Terrorism Act 2000 (TA)

The TA, as amended, establishes several offences about engaging in or facilitating terrorism, as well as raising or possessing funds for terrorist purposes. It establishes a list of organisations the Government believes are involved in terrorism.

The Terrorism Act applies to all persons. There is a failure to disclose offence and tipping off offences for those operating within the regulated sector.

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Section 18 money laundering

It is an offence to enter into or become concerned in an arrangement facilitating the retention or control of terrorist property by, or on behalf of, another person including, but not limited to the following ways: By concealment By removal from the jurisdiction By transfer to nominees

It is a defence if you did not know, and had no reasonable cause to suspect, that the arrangement related to terrorist property.

Section 21A- tipping off

It is a criminal offence for those in the regulated sector who fail to make a disclosure to either a constable or the firm's nominated officer where there are reasonable grounds for suspecting that another person has committed an offence.

Section 21D (1) and (3) tipping off offences

Section 21D (1) disclosing a suspicious activity report (SAR). It is an offence to disclose to a third person that a SAR has been made by any person to the police, HM Revenue and Customs, SOCA or a nominated officer, if that disclosure might prejudice any investigation that might be carried out as a result of the SAR. Section 21D (3) disclosing an investigation. It is an offence to disclose that an investigation into allegations relating to terrorist property offences is being contemplated or carried out if that disclosure is likely to prejudice that investigation. Section 21E Disclosures within an undertaking or group etc It is not an offence if an employee of a firm discloses that a SAR has been made if it is to an employee of the same business.

Any concerns with regard to tipping off should be referred to the MLRO

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European Union Wire Transfer Regulations 1781/2006

This regulation applies to our business as we transfer money on behalf of clients. Its basic aim is to ensure that complete information on the person sending money (payer) is sent with the transfer to the beneficiary (payee). It is to enable law enforcement to detect and trace the assets of criminals or terrorists. We must also identify and verify customers who transfer in excess of 900, 00. For payments within the EU we need only send a name and account number.

Payment Service Regulations 2009

The regime originates from a European Community law The Payment Services Directive (PSD). The aim of the PSD is to foster a single market in retail payment services across the European Economic Area by removing barriers to entry and ensuring fair market access to enhance competition in payment services; and establishing the same set of rules across the EEA on information requirements and other rights and obligations that will be applicable to many payment services transactions in the EEA. UK BRIBERY 2010

The Bribery Act 2010 came into force on 1 July 2011. it amends and reforms the UK criminal law and provide a modern legal framework to combat bribery in the UK and internationally. The Bribery Act creates the following offences: 1) Active bribery: promising or giving a financial or other advantage 2) Passive bribery: agreeing to receive or accepting a financial or other advantage 3) Bribery of foreign public officials 4) The failure of commercial organisations to prevent bribery by an associated person

Under the current law imprisonment for up to seven years with unlimited fine will increase under the Bribery Act to a maximum of 10 years imprisonment.

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SW complying with the new regulation produced a Small World Group Anti-Bribery Policy: covering the giving and acceptance of bribes and distributed to all directors, employees and agents.

HM Treasury AFU

HM Treasury maintains a list of sanctioned individuals and countries with whom any financial dealing is restricted. It is a criminal offence to make payments or allow payments to be made to these targets. Sanctions are incorporated into UK law by EC Regulations or by statutory instruments.

In general terms, any person to whom the relevant Statutory Instrument applies who, except under the authority of a licence granted by HM Treasury under the relevant Statutory Instrument, makes any funds, economic resources or, in some circumstances, financial (or related) services available directly or indirectly to or for the benefit of persons listed under the relevant Statutory Instrument or EC Regulation is guilty of an offence.

The MLRO undertakes regular client screening against the relevant databases including whenever an update is issued by the AFU. As noted above any client is automatically screened using the Bridger Insight platform. Lists included in the Bridger Insight screening are:

Bank of England Consolidated List UK HM Treasury List UK FSA Bureau of Industry and Security List Consolidated List - Australia Consolidated List - Canada DTC Debarred Parties European Union Consolidated List FBI Hijack Suspects FBI Most Wanted FBI Most Wanted Terrorists FBI Seeking Information FBI Top Ten Most Wanted Hong Kong Monetary Authority List Interpol Most Wanted Monetary Authority of Singapore List Nonproliferation Sanctions, U.S. Department of State, ISN OFAC Non-SDN Entity List OFAC Sanctions OFAC's Specially Designated Nationals & Blocked Persons

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Politically Exposed Persons Primary Money Laundering Concern Primary money laundering concern - Jurisdictions Terrorist Exclusion List Unauthorized Banks United Nations Consolidated List World Bank Debarred Parties World Bank Ineligible Firms Terrorist Exclusion List Reserve Bank of Australia Primary Money Laundering Jurisdictions Peoples Bank of China (PBC) OSFI Country OSFI Consolidate List OIG Exclusions Offshore Financial Centers Japan MOF Sanctions Japan Meti-WMD Proliferators Japan FSA Ireland Financial Regulator unauthorized firms HVD LDP Hong Kong Monetary Authority HM Treasury Investment Ban list Foreign Agents Registrations FATF Financial Action Task Force Commodity Future Trading Comission Sanction Chefs of State and Foreign Cabinets Members Australia Dept of Foreign affairs and trade EPLS

In accordance with the MLR 2007, LCC Trans-Sending Ltd is subscribed to HM Treasurys email alert system at www.hm treasury.gov.uk/fin_crime_mailinglist.htm. All new alerts and updated received from HM Treasury are reported in our AML Monthly Report.

All customers and beneficiaries names are checked against international lists of sanctioned targets. The system is able to make this check against more than 25 international sanction lists using the Bridger Insight platform.

If a similar matching result is found, we do the following: Apply EDD and add customer to our internal watch list in order to carry out ongoing monitoring. If an exact matching result is found, we do the following: Make a disclosure to the relevant authority (Asset Freezing Unit or SOCA) and block the customer in our operational system until consent is given to proceed or refuse. In addition, we may cease the business

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relationship with the customer allowing 30 days notice to comply with out Terms & Conditions.

The Money Laundering Regulations 2007

The Money Laundering Regulations 2007 repeal and replace the Money Laundering Regulations 2003. They set requirements for the anti-money laundering regime within our business and outline the scope of customer due diligence.

The regulations aim to limit the use of MSB for money laundering by requiring businesses to know their clients and monitor the use of their services by clients.

Regulation 3 (1) of the 2007 MLR provides:

3 (1)

Every person who carries on relevant business in the United Kingdom must --

(a)

Comply with the requirements of regulations 4 (identification procedures), 6 (record-keeping procedures) and 7 (internal reporting procedures);

(b)

Establish

such

other

procedures

of

internal

control

and

communications as may be appropriate for the purposes of forestalling and preventing money laundering; and

(c)

Take appropriate measures so that employees are --

(i) Made aware of the provisions of these Regulations and of section 340 (11) of POCA; and

(ii) Given training in how to recognise and deal with transactions which may be related to money laundering.

In respect of 3(1)(b) above, the overall responsibility for implementing internal control procedures, including compiling this section of the office manual is with the Compliance Director Nicholas Day, who is assisted by the Training Manager and MLRO Fatima Maria Oliveira Fernandes.

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In respect of 3(1)(c) above, training is provided to all new employees, and to all relevant staff when there is a change in the legislation. All employees will have updated training in any event every year.

HMRC MLR 8

HMRC is the supervisory authority for all MSBs. They produce guidance for the industry which should be followed in order for the business to be fully protected from any regulatory action. MLR8 is the approved document all MSB should consider when formulating their AML policies. This manual has been prepared in accordance with HMRC, FSA and JMLSG Guidance.

CDD

This section sets out the standard identification requirements for our customers who are private individuals. This is likely to be sufficient for most situations. If, however, the customer or transaction is assessed as presenting a higher money laundering or terrorist financing risk, in line with our identified risk matrix, then we require additional identity information to be provided and increase the level or verification accordingly.

Where the result of the standard verification check gives rise to concern or uncertainty over identity, the number of matches that will be required to be reasonably satisfied as to the individuals identity will increase. Any concerns must be notified to the MLRO.

Staff may also need to follow this guidance when identifying, and verifying the identity of beneficial owners and any other relevant individuals associated with the relationship or the transaction. Any issues relating to beneficial owners should be raised with the MLRO or director of compliance.

All documentary evidence must be dated within the past 3 months and the date of expiry noted on the system. Staff will be prompted by the system when any ID is due to expire and will need to request further material from customers before the transaction may continue or account operate.

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For the purposes of Regulation EC 1781/2006 on information on the payer accompanying transfers of funds (commonly known as the Payments Regulation or the Wire Transfer Regulations), for amounts of between 1,000 euro (approximately 900), and 15,000 euro (approximately 12.500), evidence of address need not necessarily be obtained. However it is this companys policy to obtain and verify evidence of the customers address. We allocate each customer with an account number. This number will be sent with the customers name to comply with the regulation.

In terms of beneficial ownership, we will ask every customer whether they are acting in their own capacity or on behalf of another person. If they are acting for another person then we will require details of such.

INDIVIDUALS

Met face to face?

Yes and normal risk obtain: Either proof of identity photo identity Or: proof of identity non photo identity and proof of address (please note P.O. boxes are not acceptable addresses)

or date of

birth (can be electronic).

No and/or higher risk (EDD) obtain: either proof of identity photo identity and an additional piece of evidence Or: proof of identity non photo identity, proof of address (please or date of birth note P.O. boxes are not acceptable addresses)

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Plus: an additional piece of evidence.

Sources of evidence List 1: Evidence of identity List 2: Evidence of address or date of birth

Acceptable photo identity

Instrument of a court appointment (such as a grant of probate,

Valid passport; or

bankruptcy); or

Valid photo card driving licence (full or provisional); or

Current council tax demand letter or statement; or

National identity card (non UK nationals issued by EEA member states and Switzerland); or

Current (within the last 3 months) bank statements, or credit/debit card statements issued by a regulated financial sector firm in the UK, EU or JMSLG equivalent jurisdiction; or

Firearms certificate or shotgun licence; or

A file note of a visit by a member of the firm to the address concerning (home visit); or

Identity card issued by the Electoral Office for Northern Ireland An electoral register search showing residence in the current or most recent electoral year (can be done via

Acceptable non-photo evidence of identity:

http://newcorp.192.com/search/index.c fm); or

Documents issued by a government department, incorporating the persons name and residential address or their date of birth. E.g.

A recent (last available) utility bill (gas, water, electricity, telephone not mobile phone bills); it must be a bill or statement of account (not correspondence); or

A current UK full driving licence old version (not

Valid photo card driving licence (full or provisional); or

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provisional licences); or Evidence of entitlement to a state or local authority funded benefit (including housing benefit and council tax benefit), tax credit, pension, educational or other grant; or Evidence of entitlement to a state or a local authority funded benefit (including housing benefit and council tax benefit), tax credit, pension, educational or other grant; or A current UK full driving licence old version (not provisional licences); or

Documents issued by HMRC, such as PAYE coding notices and statements of account (NB: employer issued documents such as P60s are not acceptable)

Documents issued by HMRC, such as PAYE coding notices and statements of account (NB: employer issued documents such as P60s are not acceptable);or

A firearms/shotgun certificate; or

End of year tax deduction certificates.

A solicitors letter confirming recent house purchase or land previous address).

When accepting evidence of identity from a customer, it is important that we make sufficient checks on the evidence provided to satisfy us of the customers identity, and that we keep a record of the checks made.

Checks on photo ID may include:

Visual likeness against the customer

Does the date of birth on the evidence match the apparent age of the customer?

Is the ID valid?

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Is the spelling of names the same as other documents provided by the customer?

Checks on secondary evidence of ID may include:

Do the addresses match the address given on the photo ID?

Does the name of the customer match with the name on the photo ID?

Electronic verification

As a secondary proof of Identification, We also screen customers on electronic verification for those that we can not have enough proof of identification in hard paper Electronic verification must be done using our software provider Safe Credit.

Electronic verification should meet a standard level of confirmation before it can be relied upon. In circumstances that do not give rise to suspicion or significant risk of impersonation fraud, the standard level of confirmation is:

One match on an individuals full name and current address, and

A second match on the full name and either his current address or his date of birth.

Where the customer is not physically present for identification purposes we must obtain further evidence of identity in line with our stated policy. This means that we will either ask for further forms of identity or perform further checks to verify the information supplied.

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The system is also able to detect linked (aggregate) transactions which are identified by:

Similar/same names/surnames Matching ID number Similar/same telephone number / address

Customers who cannot provide the standard evidence

Some of our customers may not be able to produce identification information to meet the standard requirement, e.g. migrant workers, refugees and asylum seekers, dependent spouses/partners or minors. In these cases we will need an approach that compensates for the difficulties that such customers may face in providing the standard evidence of identity.

We must record why the standard requirements cannot reasonably be applied.

The following table provides examples of documents that provide evidence of identity for some types of financially excluded customers. The list is not exhaustive. Any problems should be referred to the MLRO.

Customer

Documents(s)

Economic Migrants

National Passport, or National Identity Card (nationals of EEA)

Refugees (Those that are not on benefit) IND travel document (i.e. Blue Convention Travel doc, or Red Stateless Persons doc, or Brown Certificate of identity doc) Immigration Status Document with Residence Permit, or

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Where we decide that a customer cannot reasonably meet the standard identification requirement, and the provisions in the table above cannot be met, we may accept as identification evidence a letter or statement from an appropriate person who knows the individual, that indicates that the person is who he says he is.

Some categories of financially excluded customers may represent a higher risk of money laundering. We will consider enhanced monitoring of transactions conducted by anyone assessed as such.

Non face to face customers

Non face-to-face customers present an inherent risk of impersonation fraud which we must take account of in framing our internal policies and procedures. The MLR 2007 requires that we apply enhanced due diligence measures, on a risk-sensitive basis, when we dont physically meet our customers.

Therefore, we must apply additional verification checks to mitigate the risk of impersonation fraud. These checks may include:

Requiring additional documents, data or information to verify the customers identity

Applying supplementary measures to verify the documents supplied

Requiring the first transaction to be carried out through an account in the customers name with a UK or EU regulated bank or one from a comparable jurisdiction.

Telephone contact with the customer at a home or business number which has already been verified, using it to verify additional aspects of personal identity information provided during the application process.

Communicating with the customer at an address which has already been verified, for example by letter.

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Photocopied identity documents can be accepted as evidence of ID provided that each copy document has an original certification by an appropriate person to confirm that the person is who they claim to be.

An appropriate person is an independent professional person who is not already a friend or relative of the applicant. For example:

Family GP

Accountants

Civil Servant

Teacher

Solicitor

Notary

Post Office Branch employee

Employer

In addition to providing a written certification on the copy document to confirm the identification of the applicant, the certifying individual should also provide their business contact details. Customers other than private individuals (such as companies)

General Obligations

Certain information about the entity should be obtained as a standard requirement. We will then assess the risk of money laundering or terrorist financing, based on the

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combination of factors outlined in our risk matrix. We will then decide the extent to which the identity of the entity should be verified, using reliable, independent source documents, data or information. We will require information in respect of some of the individuals behind or connected to the customer for the purpose of being satisfied that we know who the beneficial owners of the entity are.

As part of the standard evidence, we must know the names of all individual beneficial owners who own or control more than 25% of the customer, even where these interests are held indirectly.

Information must be obtained on the nature and purpose of the business relationship and anticipated size and volume of transactions. We do this by asking our clients to complete our Basic Information Report. See attached B

Corporate customers We will obtain the following as standard in relation to corporate customers:

Full Name

Registered Number

We will also verify the identity of the corporate entity from:

Either a search of the relevant company registry

Or confirmation of the companys listing on a regulated market (see the FSA handbook glossary for a definition of regulated market)

Or a copy of the companys certificate of incorporation

This standard evidence is likely to be sufficient to verify the identity of most corporate customers. If, however, any of the circumstances outlined in our risk matrix exist then

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require additional information to be provided in order to be satisfied as to the customers identity, including, where appropriate, the nature and purpose of the customers business activities and the source of funds.

In general the structure, ownership, purposes and activities of many private companies will be clear and understandable.

The standard evidence above on corporate customers should be obtained and verified, plus, additionally, the following information should be obtained and verified:

Names of all directors (or equivalent)

Names of beneficial owners/shareholders holding over 25%

Names of all directors (or equivalent)

Other entities

Further guidance on verifying the identity of a range of non-personal entitles is provided in the JMLSG Anti-Money Laundering guidance for FSA regulated firms.

If any of these types of organisation wish to use our service please refer the matter to the MLRO.

PROCEDURE FOR REPORTING SUSPICIOUS CIRCUMSTANCES

Any member of staff, who is suspicious that a transaction may involve money laundering or who becomes aware in the course of their work that someone else is involved in money laundering, must make a disclosure to the MLRO using the report form found in attachment. Copies of the report form are also to be found in the central Database

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Once completed, the form should be printed off. The member of staff making the report must sign and date the form or click on suspicious box in the system to create a digital ISAR which will be sent automatically to the MLRO.

The form must then be hand delivered by the reporting member of staff to the MLRO. The MLRO will sign a receipt to show date and time of report.

Upon receipt of the form by the MLRO, they will then decide what is to be done as a result of the report, e.g., whether the matter must be reported to the SOCA or not, or further enquiries made and record its decision and the reason for it on the report form on the Database. The member of staff concerned must be informed of the decision and the reasons for it.

If the matter is referred to the SOCA the MLRO will be responsible for completing the SOCA report form and discussing with the reporting member of staff how matters with the client/transaction are to be conducted from that stage, bearing in mind that POCA prohibits us from continuing with the prohibited act which is being reported to SOCA. The SOCA report form must be signed off by the MLRO or her deputy or, in both of their absence, a director.

In accordance with the tipping off provisions of POCA, the report must not be discussed with the customer.

We must not proceed with a transaction whilst we await consent from SOCA. SOCA is given 7 working days (sat/sun or bank holidays not included) to consider the report.

If we hear nothing then we may continue with the transaction but not inform the client about the report. SOCA may give consent to proceed earlier than this time limit. They may also refuse consent in which case they have a further 31 calendar days (including sat/sun or bank holidays) to further consider the report. After this they must either begin proceedings or allow the transaction to continue. Attached M shows our SOCA reporting timetable.

The MLRO will report using one of the existing standard methods and in the majority of cases will utilise SAR Online. (www.soca.gov.uk).

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If the MLRO decides to use any other method fax, disc, CD ROM or post she will use the standard SARs form, which must be typed.

Any paper file for each matter will be kept by the Compliance director, who should be notified of each matter.

There must be no record on the Customer file or on the computer system which refers in any way to suspicious circumstances reporting, money laundering, etc., to avoid the risk of tipping off. It is a criminal offence to inform a customer that a SAR has been submitted, or to inform them of an investigation into their affairs. All records of SAR will be kept in the central reporting file, which is kept in the MLROs office.

Suspicion Indicators The following lists are provided for staff as an aid to whether a particular transaction may be suspicious. The list is not exhaustive and staff should consider all the circumstances of a particular transaction before deciding whether to report any issues to the MLRO.

New customers and occasional or one-off transactions:

Checking identity is proving difficult. The customer is reluctant to provide details of their identity. There is no genuine reason for the customer using the services of an MSB A cash transaction is unusually large. The cash is in used notes and/or small denominations. The customer requests currency in large denomination notes. The customer will not disclose the source of cash. The explanation for the business and/or the amounts involved is not credible. A series of transactions are structured just below the regulatory threshold for due diligence identity checks. The customer has made an unusual request for collection or delivery. Transactions having no apparent purpose or which make no obvious financial sense, or which seem to involve unnecessary complexity. Unnecessary routing of funds through third parties.

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Regular and established customers.

The transaction is different from the normal business of the customer. The size of frequency of the transaction is not consistent with the normal activities of the customer. The pattern of transactions has changed since the business relationship was established. Money transfers to high-risk jurisdictions without reasonable explanation, which are not consistent with the customers usual foreign business dealings. Sudden increases in the frequency/value of transactions of a particular customer without reasonable explanation.

Examples where customer identification issues have potential to indicate suspicious activity.

The customer refuses or appears reluctant to provide information requested. There appears to be inconsistencies in the information provided by the customer. The customers area of residence is inconsistent with other profile details such as employment. An address appears vague or unusual. The supporting documentation does not add validity to the other information provided by the customer. The customer is in a hurry to rush a transaction through, with promises to provide the information later.

Examples of activity that might suggest to staff that there could be potential terrorist activity.

The customer is unable to satisfactorily explain the source of income. Frequent address changes. Media reports on suspected or arrested terrorists or groups.

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SAR PROCEDURE
If Necessary further information about circumstances obtained Report any suspicions STOP TRANSACTION If Appropriate Submit SAR

STAFF

Use internal report form No information as to suspicions to customer

MLRO

SOCA

Uses prescribed method

No report deemed necessary

SAR FILE
Keep records for 5 years

7 working daysconsent given 7 working days No consent

Transaction Customer

Continue as normal. No information to client about report

LCC

Consent
31 calendar days No information on report To be given to customer

Transaction Refused

No Consent

LCC

RECORD KEEPING

CDD and transaction records

We will store records of all transactions for 5 years from the conclusion of the transaction on behalf of our customers or the end of the relationship.

The records we must keep are:

1.

copies of or references to the evidence of the customers ID obtained under our CDD requirements; and

2.

the supporting evidence and records in respect of the business relationships and occasional transactions, which are subject of CDD or ongoing monitoring.

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All records of CDD documentation are scanned and upload into our operational system linked in the customer unique reference number. INTERNAL AND EXTERNAL SAR RECORDS

As previously indicated, all internal reports will be kept on the SAR file as opposed to the customer file. The report will be kept for 5 years.

In addition to this all SAR submitted including correspondence with SOCA or HMRC will be kept for unlimited period of time. TRAINING RECORDS

The company maintains records of all AML training undertaken by staff, the date it was provided and the results of any tests if applicable. These records will be kept for 5 years following the end of employment with the company.

AGENTS RECORDS

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ANNEX I

Terms & Conditions

Ant-Money Laundering and Bribery Prevention Policies and Procedures

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TERMS AND CONDITIONS

As used in our Terms and Conditions, the terms: "Prohibited purpose" means any unlawful purpose; the purpose of making or receiving payment for gambling services, gambling chips or gambling credits; the purpose of making or receiving payment for banking or other financial services; or the purpose of sending a payment to yourself as the recipient; "Recipient" means the person identified as the beneficiary of a money transfer (whether that money transfer is initiated by a sender using the Service or by a person using another money transmission service); "Sender" means the person who initiates the carrying out of a money transfer by using Service; Authorised person is the person who is formally and properly empowered to perform on behalf of the sender. "Transaction" means each money transfer that you initiate under, and each other use that you make of, the Service; "We", "our" or "us" means LCC Trans-Sending, Ltd., which is a company incorporated under the laws of England and Wales and whose registered office is at Units 3-4 Sycamore Court, 168-170 Bermondsey Street, SE1 3TQ London. "Service" means any or all of the services for money transfer which are made available by us; "Site" means the website operated by us to provide online money transmission services and related information facilities; UTN means the unique transaction number which will be issued to you and which the recipient will required to provide in order to authorise us or our agents to make payment to the recipient; and "You" or "your" means any person who uses the Site or the Service, whether as a sender or as a recipient. Business Day means official working hours excluding weekends and public holidays. Value Date : means the date on which a transaction actually takes place. Payment order means the instruction to transfer funds sent via paper and/or electronic means. All references in Our Terms (unless otherwise stated) (a) to a person or persons shall include any natural person, company, firm, partnership, trust, public body or other organisation; (b) to clauses are to clauses of Our Terms; (c) to any legislation (including statutes, statutory instruments, statutory provisions or regulations) shall include them as amended or re-enacted from time to time; and (d) made in the singular shall include the plural and vice versa.

1 1.1

MONEY TRANSFERS - OUR OBLIGATIONS Before agreeing to undertake a transaction we will provide you with a draft contract or payment order which, together with these Terms, will set out the information which we are obliged to provide to you (a) (b) The maximum total fee that the Sender will be charged by us, together with a breakdown where applicable. If we believe that person to whom you send the money may also have to pay a fee, then we will tell you. An indication of the exchange rate that we will apply to your transaction, or the reference exchange rate upon which the actual exchange rate will be based. If a further exchange rate may be applied we will tell you to expect this. Information on where the person should collect the money from and what they have to do, if it is to be made available in cash An indication of the maximum time that it will take for the transaction to be completed i.e. the time until funds will be available to the person to whom you are sending the money. Information on cancellation procedures and any charges for cancelling or amending a transaction In relation to any Money Transfer that we have agreed to perform for you, (a) if we are in receipt of your onward payment instructions by the Value Date and time we specify, as soon as practicable after the Value Date (or, if the Value Date is not a Business Day, as soon as practicable after the first Business Day following the Value Date); or (b) if we are not in receipt of your onward payment instructions by the Value Date and time we specify, as soon as practicable after we have received your onward payment instructions, but you should be aware that it can take more than 5 (five) Business Days for the funds to clear, depending on local banking arrangements.

(c) (d) (e) (f)

1.2 (a) (b) (c) (d) (e) (f) (g) (h)

Upon completion of a transaction we will provide you with the following in writing: A transaction reference number that is unique to your payment Confirmation of the exact amount we are sending for you The charges or fees that you have paid to us for this service, together with breakdown where applicable. The amount of the Transaction in the currency used in the payment order. The amount of the Transaction in the currency in which the Recipient will receive the money. The date on which we received the payment order from the Sender. The exchange rate that has been applied to your transaction Information on where the person to whom you are sending the money can collect it or confirmation of the bank to which the money has been sent

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(i) (j) (k)

When the money will be available for the person to whom you are sending it and whether this timescale is definite or the best estimate that we can make In the case of cash collections, what the beneficiary has to do in order to collect the money. The procedure to follow if you have a need to query this transaction. We will advise you how long it will take us to provide an answer or an update. Our agreement with you is that we will take reasonable care to provide the Service. As such, we agree to provide you with the money transfer services and the related information facilities made available from time to time by us. We do not accept any responsibility to you for: the goods or services which you pay for by using the Service; malfunctions in communications facilities which cannot reasonably be considered to be under our control and that may affect the accuracy or timeliness of messages you send to us; any losses or delays in transmission of messages arising out of the use of any Internet access service provider or caused by any browser or other software which is not under our control; viruses caused by third parties; We have no obligation to you to initiate or perform a money transfer or other transaction as part of the Service if: we are unable to obtain satisfactory evidence of your identity; we have reason to believe that the transaction message is incorrect, unauthorised or forged; you provide us with incorrect or incomplete information or if your send order is not given to us sufficiently in advance to allow for timely provision of the requested transaction, and we do not accept any liability for damages resulting from non-payment or delay in payment of a money transfer to a recipient or failure to perform a transaction under the Service by reason of any of these matters. The information the Sender needs to provide in order for the transaction to be executed: Senders full name, address, date of birth, phone number, nationality, occupation, Identification (passport, drive licence or EEA ID) for all transactions, and proof of source of money for transactions equal or greater than Euros 5000 per month. Beneficiarys full name, phone number, account number, bank name. We may request further information if necessary. We may refuse to provide the Service (in whole or in part) to you if we understand that you dont have enough information to follow the regulatory or governmental authority. We may suspend the operation of the Service in whole or in part if, in our absolute discretion, we consider it appropriate to do so by reason of any circumstances beyond our control. We undertake that if the Service is interrupted (whether by us, any third party service provider or otherwise) for any reason we will take reasonable care to minimise the duration of any interruption. Provided we comply with this undertaking, we shall not be liable to you for any loss or liability which may be suffered or incurred by you as a result of any such interruption, even if caused by our negligence, except where any such interruption is caused by our fraud.

1.3

1.4 (a) (b) (c) (d) 1.5 (a) (b) (c)

1.6 (a)

(b) (c) 1.7

1.8

2 2.1

MONEY TRANSFERS - YOUR OBLIGATIONS You agree to pay our charges for each money transfer or other transaction which you initiate or request under the Service. Before we can perform any of Our Services for you, you must register with us. In order to complete your registration, you must provide us with all the details we require from you, including details relating to your identity and proof of address and any other information we may require from you to enable us to complete our antimoney laundering procedures.

2.2

You will promptly supply us with all information and documentation which we may ask you for at any time to enable us to comply with any legal requirements on us relating to our Services, including as required by Third European Directive 2007. You may authorise another living individual to provide us with instructions on your behalf. In these circumstances, we will treat the instructions of the Authorised Person as if they came from you. You are responsible for the completeness and accuracy of all information you provide to us at any time, including any in your request and your nominated account details. You must always provide us with instructions, and make sure any authorised person provides us with instructions, in the English language. You acknowledge and agree that: when you register with us or submit a send order, you will provide us with true, accurate, current and complete information and sign the receipt to confirm it; you will maintain and promptly update such information to keep it true, accurate, current and complete; you will not use the Service for or in connection with any prohibited purpose; you will not initiate a money transfer or other transaction under the Service in breach of these Terms and Conditions or any other restriction or requirement of use described on the Site; and You are responsible for the security of the UTN. You acknowledge and agree that information about you, and the services we provide to you are confidential, however may be provided by us from time to time to regulatory or governmental authorities, bodies or agencies where we are required by law to do so. All information must be kept in our data base for up 5 years.

2.3

2.4

2.5 (a) (b) (c) (d) (e) 2.6

2.4 2.7 2.8

All currency converted under the Service is converted at our rate of exchange. You will be liable to us for all losses which we suffer or incur relating to any fraudor fraudulent activity by you at any time. CANCELLATION AND REFUNDS

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3.1

You have the right to cancel orders up to the time at which payment has been made to the recipient. You may exercise this right by: (a) telephoning us on (+44) 020 7378 1100; (b) writing to us at Units 3 -4 Sycamore Court, 168-170 Bermondsey St, SE1 3TQ; (c) sending us a fax to (+44) 020 7378 1220; or (d) e-mailing us at customerservice.uk@smallworldfs.com We will accept any notice which indicates, in whatever form of words that you wish to cancel your agreement with us. If you exercise your right to cancel under clause 3.1 after you have sent a money transfer order to us, we will reimburse any payments which you made to us before cancellation, but: We will not reimburse you if we have paid the money transfer to the recipient before we receive your notice of cancellation. We may make a cancellation charge if the reason for the return of the money is not caused by our part, only the net value of the transfer will be reimbursed. We will keep the commission previously charged. Reimbursed cannot exceed 10% of the total value of the payment including commission. If we can not complete de transfer for any reason, we will immediately contact you in order to make the reimbursement. Your right of cancellation under laws relating to contracts is in addition to your right as sender upon request to us (by using any of the methods described in clause 3.1 above) to receive a refund of the principal amount of a money transfer (at our exchange rate applicable at the time the refund is made) if payment is not made to the recipient within 45 days. If the beneficiary does not collect their transfer within 13 months, then all rights of cancellation or refund of the money transfer or commission will be waived. If you made a deposit in our account (Barclays PLC or Lloyds TSB) and failed to identify or proceed the transaction in our Call Centre within 30 days, then all rights of cancellation or refund of the money transfer or commission will be waived and the amount remaining in our account without owner identification will be given to Charity. We are not responsible and we will not refund you for payments done incorrectly by our corresponding payer should you provide the company with one or more wrong payment information.

3.2 (a) (b)

3.3

3.4

3.5

3.6

4 4.1

SECURITY Upon making a send order through the Service we will issue you with a UTN. In order for us to authorise payment to a recipient, the recipient must provide us or our pay-out agent with the following: photographic identification (such as a passport or identity card); the exact amount of the principal amount of the send order; and the UTN relating to the send order.

(a) (b) (c) 5 5.1

LIABILITY We will refund to you any benefit which we receive as a result of any breach of our agreement with you or other wrongdoing (this means that, for example, where a money transfer has failed in such circumstances we will refund to you the principal sum and the service charge). If you or a recipient suffers any loss we will only accept liability for that loss up to a limit which is the greater of: (a) the amount of any service charge; and (b) 250, unless otherwise agreed by us in writing. Our liability only limits a claim for loss arising out of any single transaction or related transactions, or (if a loss does not arise out of a transaction or transactions) any single act, omission or event or related acts, omissions or events. We do not, in any event, accept responsibility for any failure to perform your instructions as a result of circumstances which could reasonably be considered to be outside our control. Nothing in this clause 5 shall (a) exclude or limit liability on our part for death or personal injury resulting from our negligence; or (b) exclude liability for our fraud. We are not liable to you for any loss or damage which you may incur: (a) (b) 5.5 as a result of any breach by you of any of the provisions set out in clauses of these Terms and Conditions Legal requirements on us, including for Money Laundering, Your relationship is with LCC Trans-Sending Ltd. only. You agree that no affiliate or agent of LCC Trans-Sending owes you any duty of care when performing a task which would otherwise have to be performed by LCC TransSending under its agreement with you. We are not liable under the Contract to any person except you and are not liable for any loss or damage whatsoever caused to any person other than you. TRANSFER OF RIGHTS 6.1 We have the right to transfer our rights and/or responsibilities under our agreement with you to an affiliated company, or any third party, at any time without your consent unless such transfer would reduce your rights and/or remedies or increase your responsibilities and/or liabilities under your agreement with us. You may not transfer your rights and/or responsibilities under your agreement with us without our prior written consent.

5.2

5.3

5.4

5.6

THIRD PARTY RIGHTS The Contracts (Rights of Third Parties) Act 1999 shall not apply to the agreement between us and accordingly nothing in it shall be directly or indirectly enforceable by any third party.

CIRCUMSTANCES BEYOND OUR CONTROL

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We are not liable to you if we are unable to perform any of our obligations to you or our performance of any of our obligations is delayed due to any circumstances outside of our reasonable control, including (without limitation) any industrial action, labour dispute, act of God, fire, flood or storm, war, riot, civil commotion, siege, security alert, act of terrorism or any resulting precautionary measures taken, act of vandalism, sabotage, virus, malicious damage, compliance with any statute, statutory provision, law, governmental or court order, the actions or instructions of the police or of any governmental or regulatory body which authorises us to perform Our Services, cut or failure of power, failure of equipment, systems or software or internet interconnectivity or the occurrence of any extraordinary fluctuation in any financial market that may materially adversely affect our ability to perform the Trade or your ability to fund the Trade. If any of these circumstances occur then the Contract shall be suspended for the period during which they continue or, at our discretion and in order to protect both you and us, we may terminate the Contract.

9 9.1 9.2 9.3

CONFIDENTIALITY We respect the privacy of the affairs of all our customers and always aim to treat customer information as confidential and to use customer information in confidence. We will not treat customer information as confidential where it is already public knowledge or where it becomes public knowledge through no fault of our own. We may disclose customer information if we are required to do so by law, by a court, by court order, to meet any statutory, legal or regulatory requirement on us, or by the police or any other law enforcement agency in connection with the prevention or detection of crime or to help combat fraud or money laundering.

10

MONEY TRANSFER AND THE PAYMENT SERVICES REGULATIONS The Payment Services Regulations 2009 (SI 2009/209) (the Regulations) govern the transfer of money to recipients within the European Economic Area (being all members states of the European Union, together with Norway, Iceland and Liechtenstein), where the transfer of funds is carried out in Euros, Sterling or the currency of another EEA state which has not adopted the Euro a its currency. The Regulations set down some rules applicable where we are requested to send on funds after the completion of a Transaction. We can provide you with further details of these rules should you require them.

11

ADDITIONAL INFORMATION RELATING TO A MONEY TRANSFER The information we are obliged to provide to you is set out at clauses 1 and 2 of these Terms. If you ask us to provide you with any information or materials which we are not required to provide under the Regulations, we may ask you to pay us a fee to cover our costs of providing them to you. If you do ask us to do this, then we will advise you of any fee that may apply.

12

COMPLAINTS We value all our customers and take our obligations seriously. We have established internal procedures for investigating any complaint that may be made against us in relation to any Money Transfer. In accordance with our complaints procedure, any complaint you may make relating to any Money Transfer must be made or confirmed to us in writing to Head of Client Services at LCC Trans-Sending Ltd,168-170 Bermondsey Street, London SE1 3TQ or by electronic message to customerservice.uk@smallworldfs.com. We shall investigate your concerns and respond to you promptly. If you are still dissatisfied following our response to any complaint, you may have a right to refer your complaint concerning the Money Transfer to the Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR. If you would like further details of our complaints policy relating to Money Transfers please contact our Head of Client Services.

13 13.1

NOTICES Where any notice is required by Our Terms to be given in writing, it must be written in the English language and: (a) Where it is to be given by you, it must be sent by email to customerservice.uk@smallworldfs.com or by post to Private Client Services at LCC Trans-Sending Ltd,168-170, Bermondsey Street, London SE1 3TQ. (b) where it is to be given by us, it must be sent by email to the last email address which we hold for you or by post to the last postal address we hold for you, or to such other email or postal address in the United Kingdom which you tell us to use by notifying us in advance in writing in accordance with the provisions of this clause. Any notice sent by email will be treated by you and us as being received on the first Business Day coming after the day on which it was sent and any notice sent by post will be treated by you and us as being received on the second Business Day coming after the day on which it was posted.

14

GOVERNING LAW Our agreement with you is governed by English law. We both agree that any dispute, claim or other matter relating to the Service will be dealt with by the English courts only.

LCC Trans Sending Limited is a company incorporated and licensed under the laws of the United Kingdom, engaged in the business of funds remittance with its Head Office located at: 168-170 Bermondsey Street, London SE1 3TQ. Email: customerservice.uk@smallworldfs.com

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LCC TRANS SENDING LTD.

ANTI-MONEY LAUNDERING POLICIES AND PROCEDURES

POLICY STATEMENT

It is the policy of this firm that all members of staff shall actively participate in preventing the services of the firm from being exploited by criminals and terrorists for money laundering purposes. This participation has as its objectives: ensuring the firms compliance with all applicable laws, statutory instruments of regulation, and requirements of the firms supervisory body protecting the firm and all its staff as individuals from the risks associated with breaches of the law, regulations and supervisory requirements preserving the good name of the firm against the risk of reputational damage presented by implication in money laundering and terrorist financing activities making a positive contribution to the fight against crime and terrorism

To achieve these objectives, it is the policy of this firm that: every member of staff shall meet their personal obligations as appropriate to their role and position in the firm commercial considerations shall never be permitted to take precedence over the firms anti-money laundering commitment the firm shall appoint a Money Laundering Reporting Officer (MLRO), and a deputy to cover in his or her absence, and they shall be afforded every assistance and cooperation by all members of staff in carrying out the duties of their appointments.

The MLRO is Fatima Fernandes and her deputy is Seanna Manita

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POLICY AND PROCEDURE FOR THE ASSESSMENT OF MONEY LAUNDERING RISK

POLICY It is the policy of this firm to assess the money laundering and terrorist financing risk presented by our clients so that we can mitigate that risk by applying an appropriate level of client due diligence. PROCEDURE 1 The money laundering or terrorist financing risk represented by each client will be assessed: 2 during the new client acceptance process, before any work is undertaken whenever the firms process of ongoing monitoring flags up a change in the business of an established client representing a change in money laundering risk

The assessment will be carried out by the responsible head of compliance: MLRO Fatima Fernandes, Compliance Director Nicholas Day, Senior Management: Christiano Simoes and Ricky Knox, Manager: Salomon Smilovitz who will judge into which of three categories the client and the business to be conducted falls: the range normally dealt with by the firm, requiring the firms normal level of client due diligence an exceptionally high level of risk requiring an enhanced level of client due diligence a negligible level of risk requiring only simplified client due diligence

In carrying out the assessment, the following factors are to be considered, and sufficient information must be obtained for it to be known whether: the individual client, or the principals of a corporate client, are locally resident, can be met in person, and have good reason for engaging this firm the identity of the client can be verified by the firms normal procedures the client is not subject to sanctions or in a category automatically requiring enhanced due diligence the products and services the firm is to provide and delivery channels to be used are vulnerable to money laundering risk significant sums are to be introduced and whether their provenance can be verified transactions are to involve other jurisdictions, and whether those have equivalent AML regulation to the firms own jurisdiction

A record must be made of the assessment, confirming that all the above factors have been taken into account, and any other relevant factors considered.

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POLICY AND PROCEDURE FOR THE VERIFICATION OF CLIENTS IDENTITY POLICY It is the policy of this firm to verify the identity of all clients, and to check that they are not the subject of sanctions or other statutory measures prohibiting the firm from providing its services. PROCEDURE 1 Where clients are an individual person or persons acting on their own behalf, the identity of the individual(s) will be verified by members of staff authorised by the firms MLRO, who will ensure that staff so authorised receive appropriate training. The member of staff conducting verification of identity will complete the process by checking that the client is not the subject of sanctions or other statutory measures, using the screening methods set out by the MLRO. Where the individual is a UK national resident in the UK, and will be seen in person by the member of staff carrying out the verification, identity will be conducted by examination of: one document confirming the individuals name, such as a passport one document confirming the individuals address, such as a utility bill this document is required even if the document confirming name also has the address

The firms MLRO will maintain a list of acceptable documents. Only originals or certified documents, not copies, will be accepted for examination. 4 In cases where a client cannot produce acceptable documents, the responsible Fatima Fernandes will make a risk-based decision on accepting the documents that are available, consulting with the MLRO if appropriate. Where the individual is not a UK national, or not resident in the UK, or will not be seen in person by the member of staff carrying out the verification, the responsible Ricky Knox will make a risk-based decision on the means of verification to be accepted, consulting with the MLRO if appropriate. Where the client is not the beneficial owner of assets involved, the responsible Compliance Team will take the necessary steps to determine who is the beneficial owner, and their identity will be verified according to this procedure in addition to that of the client. Where the client is a corporate entity such as a private limited company, the responsible compliance team will check that the entity is appropriately incorporated and registered, and take the necessary steps to determine who are the principal beneficial owners, and who exercises control, and their identity will be verified according to this procedure. Where the client is a listed company or a regulated firm, the responsible compliance team will check that the client is appropriately registered, and that the person with whom the firm is dealing is properly authorised to act on the clients behalf, and will verify the identity of that person according to this procedure, in addition to that of the client entity. In all cases where enhanced client due diligence is required the responsible compliance team and supervisors will consult with the MLRO to decide on additional steps to verify the clients identity.

10 All verification of identity processes will be recorded. This will include keeping photocopies of documents produced, or in exceptional cases with the approval of the MLRO, recording information about where copies are held and can be obtained.

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POLICY AND PROCEDURE FOR KNOWING THE CLIENTS BUSINESS AS PART OF CDD
POLICY It is the policy of this firm to obtain information enabling us to understand every clients reason and purpose in using the services of the firm. This Know Your Clients Business (KYCB) information will enable us to maintain our assessment of the on-going money laundering risk, and notice changes or anomalies in the clients arrangements that could indicate money laundering. It is the policy of this firm not to offer its services, or to withdraw from providing its services, if a satisfactory understanding of the nature and purpose of the clients business with us cannot be achieved. PROCEDURE 1 The responsible supervisors, staff and compliance team will obtain KYCB information from clients: on acceptance of a new client on receipt of a new instruction from a client whose arrangements are of a one-off nature on any significant change in the clients arrangements such as the size or frequency of transactions, nature of business conducted, involvement of new parties or jurisdictions as an ongoing exercise throughout the client relationship

KYCB information sought from clients will include, but not be limited to: the clients reason for choosing this firm the purpose behind the services the client is asking the firm to provide the provenance of funds introduced or assets involved in the clients arrangements the nature, size, frequency, source and destination of anticipated transactions the counter-parties and jurisdictions concerned

The information will be obtained by asking the client pertinent questions in the course of normal conduct of the relationship. Answers given by the client will be recorded on the client file, to assist with future monitoring of the client relationship. Answers given by the client will be verified where this is possible within the normal conduct of the relationship, or by using readily available information sources. Answers not readily verifiable should nevertheless be considered together with other details known about or given by the client to check that all the information is consistent and plausible. Where answers given by the client are implausible, or inconsistent with other information, or where the client is unwilling to provide satisfactory answers to due diligence enquiries, the responsible compliance team will consider whether the firm should withdraw from the relationship.

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POLICY AND PROCEDURE FOR ONGOING MONITORING OF CLIENTS ACTIVITIES POLICY It is the policy of this firm to monitor clients instructions and transactions to ensure that they are consistent with those anticipated, that possible grounds to suspect money laundering will be noticed and scrutinised, and that changes requiring a re-assessment of money laundering risk will be acted upon. PROCEDURE 1 All significant client instructions and transactions will receive the attention of the responsible supervisors and compliance team who will consider whether they are consistent with those anticipated. Where a clients instruction or transaction is not consistent with what is anticipated: 3 an explanation will be sought, if appropriate by contacting the client the involvement of unexpected jurisdictions or organisations will be checked with the firms MLRO for possible alerts or sanctions if a satisfactory explanation is found, the client file will be updated with that explanation and to reflect the change in anticipated client activities if no satisfactory explanation is found, the responsible compliance team will consider whether there are grounds to suspect money laundering. the responsible Fatima Fernandes will consider whether there is cause to carry out a re-assessment of money laundering risk, and if so to carry this out

The responsible Fatima Fernandes will supplement the training provided to support staff by giving guidance on: the type of client instructions and transactions that count as significant and so should be brought to their attention noticing client instructions and transactions which, although not of a nature normally counting as significant, are in some way unusual or anomalous and should be considered with regard to possible suspicion of money laundering

Irrespective of whether specific incidents have caused a re-assessment of money laundering risk, every client file will be reviewed periodically to check that the information held is still adequate, correct and up to date the level of client due diligence being applied is still appropriate

Periodic review of client files will be conducted annually.

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POLICY AND PROCEDURE FOR KEEPING RECORDS OF CLIENT DUE DILIGENCE INFORMATION
POLICY It is the policy of this firm to keep records of enquiries made and information obtained while exercising client due diligence for AML purposes, and to ensure that these records are retained as required for legal and regulatory stipulations. These records will include but not be limited to details recorded for accounting and business development purposes. PROCEDURE 1 When information is being collected for AML client due diligence, the responsible Supervisors and Compliance team will: 2 keep records in the client file, or other appropriate place, of details collected personally record instances where information requested has not been forthcoming, or explanations provided have not been satisfactory ensure that staff undertaking AML due diligence enquiries on their behalf keep records in the appropriate places ensure that all records are kept in a consistent manner so that they are accessible by and comprehensible to other authorised members of staff, including the MLRO

CDD records will routinely be archived along with the firms accounting records to ensure their availability for a minimum of five years from the date of the completion of the transaction or enquiry. For clients who have been subject of a suspicion report, relevant records will be retained separately from the firms routine archives, and not destroyed, even after the five year period has elapsed, without confirmation from the MLRO that they are no longer required as part of an enquiry.

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POLICY AND PROCEDURE FOR INTERNAL SUSPICION REPORTING

POLICY It is the policy of this firm that every member of staff shall remain alert for the possibility of money laundering, and shall report any and every suspicion for which they believe there are reasonable grounds, following the firms procedure. The expectation placed on each individual member of staff in responding to possible suspicions shall be appropriate to their position in the firm. No-one is expected to have a greater knowledge and understanding of clients affairs than is appropriate to their role. PROCEDURE 1 Every member of staff must be alert for the possibility that the firms services could be used for money laundering purposes, or that in the course of their work they could become aware of criminal or terrorist property. Alertness to the possibility of money laundering must be combined with an appropriate knowledge of clients normal arrangements so that members of staff become aware of possible causes of suspicion. A member of staff becoming aware of a possible suspicion shall gather relevant information that is routinely available to them and decide whether there are reasonable grounds to suspect money laundering. Any additional CDD information acquired, in particular any explanations for unusual instructions or transactions, should be recorded on the client file in the routine manner, but there must be no mention of money laundering. The requirement to gather relevant information does not extend to undertaking research or investigation, beyond using information sources readily available within the firm. Clients may be asked for relevant information, but only in the context of routine client contact relevant to the business in hand. If after gathering and considering routinely available information, the member of staff is entirely satisfied that there are no grounds for suspicion, no further action should be taken. A member of support staff who on consideration decides that there may be grounds for suspicion shall in normal circumstances raise the matter with the responsible Fatima Fernandes. If after discussion they both agree that there are no grounds for suspicion, no further action should be taken. No member of staff is obliged to discuss a suspicion of money laundering with the responsible Supervisors They may, if in the circumstances they prefer, contact the MLRO directly. If following the raising of a possible suspicion by a member of staff, or resulting from their own observations, the responsible Fatima Fernandes decides that there are reasonable grounds to suspect money laundering, he or she must submit a suspicion report to the MLRO, in the format specified by the MLRO for that purpose. An internal suspicion report does not breach client, and no member of staff shall fail to make an internal report on those grounds.

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10 If a suspicion report results from a matter raised by a member of support staff, the responsible Fatima Fernandes must advise them in writing that a report has been submitted by reference to the matter discussed on the given date, without including the name of the person(s) suspected. This confirms to the member of staff who raised the matter that their legal obligation to report has been fulfilled. 11 In the circumstance where any member of staff forms a suspicion of money laundering but the responsible Fatima Fernandes does not agree that there are reasonable grounds for suspicion, the member of staff forming the suspicion must fulfil their legal obligation by submitting a money laundering suspicion report to the MLRO, in the format specified by the MLRO for that purpose. ( form enclose to this manual) The responsible Fatima Fernandes must recognise this legal requirement and assist the staff member in fulfilling it. 12 A member of staff who forms or is aware of a suspicion of money laundering shall not discuss it with any outside party or any other member of staff unless directly involved in the matter causing suspicion. 13 No member of staff shall at any time disclose a money laundering suspicion to the person suspected, whether or not a client, or to any outside party. If circumstances arise that may cause difficulties with client contact, the member of staff must seek and follow the instructions of the MLRO. 14 No copies or records of money laundering suspicion reports are to be made, except by the MLRO who will keep such records secure, and separate from the firms client files and other repositories of information.

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POLICY AND PROCEDURE FOR FORMAL DISCLOSURES TO THE AUTHORITIES

POLICY It is the policy of this firm that the Money Laundering Reporting Officer Fatima Fernandes (or if absent, the deputy Seanna Manita) shall receive and evaluate internal suspicion reports, and decide whether a formal disclosure is to be made to the authorities. If so deciding, the MLRO will make the formal disclosure on behalf of the firm, using the appropriate mechanism. PROCEDURE 1 On receipt of money laundering suspicion report from a member of staff, the MLRO shall acknowledge its receipt in writing, referring to the report by its date and unique file number, without including the name of the person(s) suspected. This confirms to the member of staff that their legal obligation to report has been fulfilled. The MLRO shall open and maintain a log of the progress of the report. This log shall be held securely and shall not form part of the client file. Following receipt of a report, the MLRO shall gather all appropriate information held within the firm, and make all appropriate enquiries of members of staff anywhere in the firm, in order properly to evaluate the report. The MLRO shall then decide whether they personally suspect, and reach a decision on the firms obligation to make a formal disclosure to the authorities. All members of staff, anywhere in the firm, shall respond in full to all enquiries made by the MLRO for the purposes of evaluating a suspicion report. Information provided to the MLRO in response to such enquiries does not breach client confidentiality/professional privilege, and no member of staff shall withhold information on those grounds. If deciding that a formal disclosure to the authorities is required, the MLRO shall make such disclosure by the appropriate means. The MLRO shall document in the report log the reasons for deciding to make or not to make a formal disclosure. The MLRO shall where appropriate inform the originator of the internal report whether or not a formal disclosure has been made. Following a formal disclosure, the MLRO shall take such actions as required by the authorities in connection with the disclosure.

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POLICY AND PROCEDURE FOR STOPPING/CONTINUING WORK FOLLOWING A SUSPICION REPORT

POLICY It is the policy of this firm that from the moment a suspicion of money laundering arises; no further work will be carried out on the matter that gave rise to the suspicion. Neither commercial considerations nor the difficulty in responding to the clients enquiries on the matter shall be permitted to take precedence over the firms legal obligations in this regard. In such circumstances the MLRO shall act with all possible speed to enable work to continue, and assist staff in any communications with the client affected. 1 PROCEDURE As soon as a member of staff forms or becomes aware of a suspicion of money laundering, no further work is to be done on the matter giving rise to suspicion. If there is any likelihood of the client becoming aware that work has stopped, for example because an anticipated transaction has not gone through, the member of staff concerned must contact the MLRO for instructions on how to handle the matter with the client. On receipt (form enclose to this report) of a suspicion report, the MLRO shall: instruct the originator of the report and any other staff involved to cease work on the matter giving rise to suspicion decide in the shortest possible time whether all work for the client concerned should be stopped, or whether other work that is not the cause of suspicion may continue, and advise relevant staff accordingly assist all affected staff in handling the matter with the client so that no tipping off offence is committed

When work for a client has been stopped, the MLRO shall carry out the evaluation of the suspicion report as quickly as possible to decide whether a disclosure must be made to the authorities. If the MLRO decides that there are not reasonable grounds to suspect money laundering, he will give consent for work to continue on his own authority. If the MLRO decides that a disclosure must be made, he will request consent to continue from SOCA as quickly as possible. On giving consent to continue, either on his own authority or on receipt of notice of consent or implied consent from SOCA, the MLRO will confirm this in writing to affected staff. If consent is refused by SOCA, the MLRO will take advice from SOCA and consult with the responsible Compliance Director Nicholas Day on the firms continuation of or withdrawal from the client relationship.

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POLICY AND PROCEDURE FOR AML TRAINING

POLICY It is the policy of this firm that all staff who have client contact, or access to information about clients affairs, shall receive anti-money laundering training to ensure that their knowledge and understanding is at an appropriate level, and ongoing training at least annually to maintain awareness and ensure that the firms legal obligations are met. The MLRO shall, in co-operation with the firms training officer, ensure that training is made available to staff according to their exposure to money laundering risk, and that steps are taken to check and record that training has been undertaken and that staff have achieved an appropriate level of knowledge and understanding. In the light of the seriousness of the obligations placed on each individual by the Law and the Regulations, and the possible penalties, the MLRO shall ensure that information about these personal obligations is available to all members of staff at all times. PROCEDURE 1 The MLRO will, in co-operation with the firms training officer, evaluate alternative AML training methods, products and services in order to make suitable training activities available to all members of staff who have client contact, or access to information about clients affairs. Suitable training will take into account: 3 the need to achieve a level of knowledge and understanding appropriate to the individuals role in the firm the need to maintain that level through ongoing refresher training the practicality of assigning different programmes to staff with different roles on a risksensitive basis the cost-effectiveness of the alternative methods and media available

The training programme will include means of confirming that each individual has achieved an appropriate level of knowledge and understanding, whether through formal testing, assessment via informal discussion, or other means Special consideration will be given to the training needs of senior management, and of the compliance team. The MLRO will: inform every member of staff of the training programme that they are required to undertake, and the timetable for completion check that every member of staff has completed the training programme assigned to them, issuing reminders to any who have not completed to timetable

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keep records of training completed, including the results of tests or other evaluations demonstrating that each individual has achieved an appropriate level of competence.

On completion of a training cycle, the MLRO will ensure the continuity of ongoing training while giving consideration to: the effectiveness of the programme completed the possible benefits of varying the methods and media used against the benefits of familiarity using the same approach the need to keep training information up to date with changes in laws, regulations, guidance and practice.

The MLRO will determine the training needs of his own role, and ensure that he obtains appropriate knowledge and understanding such as is required to fulfil his obligations.

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POLICY AND PROCEDURE FOR THE MONITORING AND MANAGEMENT OF COMPLIANCE

POLICY It is the policy of this firm to monitor our compliance with legal and regulatory AML requirements and conduct an annual AML compliance audit, the findings of which are to be reported to the firms Senior Management together with appropriate recommendations for action. The firms Senior Management shall provide the necessary authority and resources for the ongoing implementation of a compliant AML regime. PROCEDURE 1 The MLRO will monitor continuously all aspects of the firms AML policies and procedures. Any deficiencies in AML compliance requiring urgent rectification will be dealt with immediately by the MLRO, who will report such incidents to the compliance director Mr. Nicholas Day and Senior Management when appropriate and request any support that may be required. The MLRO will conduct an annual audit of the firms AML compliance, and report its findings to the firms Senior Management. This report will include: a summary of the firms money laundering risk profile and vulnerabilities, together with information on ways in which these are changing and evolving a summary of any changes in the regulatory environment(s) in which the firm operates a summary of AML activities within the firm, including the number of internal suspicion reports received by the MLRO and the number of disclosures made to the authorities details of any compliance deficiencies on which action has already been taken, or need to be taken, together with recommended actions and management support required. an outline of plans for the continuous development of the AML regime, including ongoing training and awareness raising activities for all relevant staff.

Where management action is indicated, the responsible Nicholas Day will respond to the report with details of appropriate action to be taken.

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BRIBERY PREVENTION POLICIES AND PROCEDURES FOR LCC TRANS-SENDING LTD

POLICY STATEMENT It is the policy of this firm that all members of staff shall actively avoid and prevent incidents of bribery involving the firm, its staff, and any persons or organisations associated with it or acting on the firms behalf. This policy has as its objectives: ensuring the firms compliance with all applicable laws and guidance, including but not exclusively the Bribery Act 2010, and requirements of the firms supervisory body protecting the firm, its principals, and all its staff as individuals from the risks associated with breaches of the law, guidance and supervisory requirements preserving the good name of the firm against the risk of reputational damage presented by implication in bribery and corrupt practices making a positive contribution to the elimination of bribery and corrupt practices within the sphere of the firms operations. To achieve these objectives, it is the policy of this firm that: every member of staff shall meet their personal obligations on bribery prevention as appropriate to their role and position in the firm, and breaches of these policies and procedures may lead to action under the firms disciplinary procedures the firm shall appoint a Bribery Prevention Officer, and a deputy to cover in his or her absence, and they shall be afforded every assistance and cooperation by all members of staff in carrying out the duties of their appointment all members of staff shall refer issues involving potential bribery offences to the firms Bribery Prevention Officer, including any knowledge or substantiated suspicion of bribery offences arrived at in the course of their work, whether or not the firm is directly involved commercial considerations shall never be permitted to take precedence over the firms anti-bribery and corruption commitment.

The Bribery Prevention Officer is Mr. Antonio Inesta

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POLICY AND PROCEDURE ON COMMISSIONS

POLICY It is the policy of this firm that the firm shall not offer or pay any commissions to individual persons, or corporate entities under their effective control, in order to induce them to act, or reward them for having acted, improperly in their employment or official capacity by favouring the firm, in breach of the Bribery Act 2010. It is the policy of this firm that no member of staff of the firm, or of any organisation appointed to act of the firms behalf, shall request or accept payment of any commission, to themselves as individuals or to the firm, as inducements to act, or reward for having acted, improperly in their employment in breach of the Bribery Act 2010. PROCEDURE 1 Payments shall not be offered or paid to individual persons, or to corporate entities which are effectively controlled by them or acting on their behalf, to induce them to act or reward them for having acted improperly by favouring the firm in business arrangements over which they have influence due to their employment, appointed position, or official capacity. Payments shall not be requested or accepted by members of staff, either personally or on behalf of the firm that may be interpreted as inducements to act, or rewards for having acted, improperly in their employment by the firm. All members of staff responsible for making or receiving legitimate payments that may reasonably fall under the heading of commissions shall assess the risk that such payments might represent a bribery risk, and if so, shall refer the matter to the firms Bribery Prevention Officer for prior approval. This policy and procedure is in addition to, and does not replace, the firms controls and approval procedures governing legitimate expenditure of this nature. The firms Bribery Prevention Officer shall maintain a record of all requests for approval of the payment of commissions, and whether approval was granted.

POLICY AND PROCEDURE ON OFFERING BUSINESS GIFTS

POLICY It is the policy of this firm that the offering of business gifts on behalf of the firm shall not be considered routine. Where the decision is made to offer a gift, its nature and value shall be appropriate and proportionate, and it shall be offered only as a token of appreciation of past business conducted, with no implication regarding future business. For the purposes of this procedure, the term gift shall include charitable donations and contributions made by the firm or in the firms name. PROCEDURE 1 Business gifts shall not be offered to potential clients or any other person when it would be likely to be seen as anticipating future business. Such gifts could be interpreted as inducements for the recipient to act improperly by favouring the firm in future business arrangements, thereby constituting a bribery offence. Where an exception to Point 1 of this procedure is thought to be appropriate, specific approval must be requested in advance from the firms Bribery Prevention Officer, irrespective of the value of the proposed gift(s). All business gifts to be offered on the firms behalf as a token of appreciation of past business must be approved in advance by the firms Bribery Prevention Officer. Approval for the offering of business gifts below the value of 100.00 may be requested on a batch basis when the gifts, their recipients, and the reasons for offering them, are similar in nature. Approval for the offering of business gifts of the value of 100.00 or above must be requested individually with details of the gift, the recipient, and the reason for offering it.
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This policy and procedure is in addition to, and does not replace, the firms controls and approval procedures governing expenditure of this nature. The firms Bribery Prevention Officer shall maintain a record of all requests for approval of the offer of business gifts, and whether approval was granted.

POLICY AND PROCEDURE ON ACCEPTING BUSINESS GIFTS

POLICY It is the policy of this firm that business gifts offered to members of staff by suppliers, clients, potential clients and other persons in connection with the firms business, shall be accepted only if appropriate and proportionate, and offered as a token of appreciation of past business conducted, with no implication regarding future business. PROCEDURE 1 Gifts shall not be accepted from clients or any other person when it would be likely to be seen as anticipating future business. Such gifts could be interpreted as inducements for the recipient to act improperly by favouring the giver in future business arrangements, thereby constituting a bribery offence. Where an exception to Point 1 of this procedure is thought to be appropriate, specific approval must be requested in advance from the firms Bribery Prevention Officer, irrespective of the value of the gift(s) being offered. Business gifts may be accepted from clients or other persons when it is clear that they are tokens of appreciation of past business conducted, without any implication regarding future business, subject to the notification and approval procedures below. Business gifts meeting the conditions of Point 3 and of the value of 200.00 or less may be accepted without prior approval, but must be notified to the firms Bribery Prevention Officer within five working days of receipt. Business gifts meeting the conditions of Point 3 but above the value of 200.00 may not be accepted without the approval of the firms Bribery Prevention Officer. Requests for approval must include details of the gift, its value, the giver, and the reason it has been given. When a business gift cannot be accepted under the terms of this procedure, it shall be declined diplomatically with the explanation that the firms procedures do not permit its acceptance. The reasons behind this must not be expressed, as it must not be implied that the offer had any improper motives. The firms Bribery Prevention Officer shall maintain a record of all notifications and requests for approval of the acceptance of business gifts.

POLICY AND PROCEDURE ON OFFERING AND ACCEPTING HOSPITALITY, ENTERTAINMENT AND SIMILAR BENEFITS
POLICY It is the policy of this firm that benefits of this nature shall be offered and accepted on behalf of the firm only in the context of enhancing business relationships with clients, potential clients, suppliers and other parties through personal contact in a non-business environment, and where the cost of the benefit is appropriate and proportionate. PROCEDURE 1 Benefits in this category shall be offered or accepted only where personal contact between members of the firms staff and the personnel of the other party is involved, and enhancement of the business relationship is actively promoted. All benefits in this category must be approved in advance by the firms Bribery Prevention Officer.

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Approval for the offering or acceptance of benefits in this category below the value of 200.00 may be requested on a batch basis when the benefits, the participants, and the reasons for offering or accepting them, are similar in nature. Approval for the offering or acceptance of benefits in this category of the value of 200.00 or above must be requested individually with details of the benefit, the participants, and the reason for offering or accepting it. This policy and procedure is in addition to, and does not replace, the firms controls and approval procedures governing expenditure of this nature. The firms Bribery Prevention Officer shall maintain a record of all requests for approval of the offer and acceptance of benefits in this category, and whether approval was granted.

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POLICY AND PROCEDURE ON OFFERING AND ACCEPTING TRAVEL AND ACCOMMODATION COSTS
POLICY It is the policy of this firm that payment for travel and accommodation costs incurred by members of the firms staff, or the personnel of suppliers, clients, potential clients and other persons in connection with the firms business, shall be offered or accepted only when the travel and accommodation in question is: necessary for the effective conduct of the firms business made use of by persons directly involved in the business in question of an appropriate level of cost considering the normal and reasonable expectations of the persons concerned.

PROCEDURE 1 Travel and accommodation costs shall be offered or accepted only when the travel is necessary for the effective conduct of the firms business, and the facilities are made use of by persons directly involved in the business being conducted. Costs meeting the conditions of Point 1 and of the value of 500.00 or less may be paid or accepted without prior approval, but must be notified to the firms Bribery Prevention Officer within five working days . Costs in this category meeting the conditions of Point 1 but above the value of 500.00 may not be offered or accepted without the approval of the firms Bribery Prevention Officer. Requests for approval must include details of the travel and accommodation, its cost, which is paying, and the reason it has been offered or accepted. When a benefit in this category cannot be accepted under the terms of this procedure, it shall be declined diplomatically with the explanation that the firms procedures do not permit its acceptance. The reasons behind this must not be expressed, as it must not be implied that the offer had any improper motives. This policy and procedure is in addition to, and does not replace, the firms controls and approval procedures governing expenditure of this nature. The firms Bribery Prevention Officer shall maintain a record of all notifications and requests for approval of the offer or acceptance of benefits in this category.

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POLICY AND PROCEDURE ON APPOINTING STAFF AND OUTSIDE PERSONS AND ORGANISATIONS
POLICY It is the policy of this firm that when appointing new staff, or outside persons or organisations to act on the firms behalf, the exposure to bribery risk of the role to be filled shall be taken into consideration. Where the risk is high, steps shall be taken to ensure that the person or organisation being appointed is of appropriate integrity, and aware of the firms policies on bribery prevention. PROCEDURE 1 When a new member of staff is to be recruited, or an outside person or organisation appointed to act on the firms behalf, the member of staff responsible for the appointment shall assess the exposure to bribery risk of the role to be filled. Where the exposure to bribery risk is high, the member of staff responsible for the appointment shall ensure that the person or organisation being considered accepts the need to comply with the law and guidance and the firms bribery prevention procedures. Appropriate steps should be taken to verify CVs, references, financial statements etc. supplied in support of the proposed appointment. If the person or organisation being considered has previous experience in roles exposed to high bribery risk, they must make clear their understanding that actions which in the were considered a normal part of doing business may now constitute offences under the Bribery Act. Where the exposure to bribery risk is high, the member of staff responsible for the appointment shall inform the firms Bribery Prevention Officer of the steps taken to ensure that the appointee has appropriate awareness and integrity.

POLICY AND PROCEDURE ON TRAINING AND COMMUNICATION

POLICY It is the policy of this firm that all staff and outside persons and organisations acting on the firms behalf shall be made aware of the firms bribery prevention policies and procedures, and that appropriate ongoing training and communication measures shall be instigated and maintained to ensure an appropriate understanding of these policies and procedures and the importance of following them. PROCEDURE 1 The firms Bribery Prevention Officer shall ensure that all members of staff, and all outside persons and organisations acting on the firms behalf, receive information making them aware of the firms bribery prevention policies and procedures, and have access to this information for reference at all times. The firms Bribery Prevention Officer shall ensure that all members of staff, and all outside persons and organisations acting on the firms behalf, receive appropriate training on the relevance and importance of bribery prevention in their everyday work. The firms Bribery Prevention Officer shall instigate and maintain an ongoing programme of assessment to ensure that all members of staff exposed to bribery risk demonstrate their awareness of bribery issues, the firms bribery prevention policies and procedures, and their importance and relevance to their work. The firms Bribery Prevention Officer shall keep records of the training received by staff and the results of awareness assessments to ensure that the firm can demonstrate that every member of staff has received appropriate training and has an appropriate level of awareness.

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POLICY AND PROCEDURE ON MONITORING AND REVIEW

POLICY It is the policy of this firm to monitor our compliance with legal and regulatory bribery prevention requirements, and conduct an annual bribery prevention compliance review, the findings of which are to be reported to the firms Senior Management together with appropriate recommendations for action. The firms Senior Management shall provide the necessary authority and resources for the ongoing implementation of a compliant bribery prevention regime. PROCEDURE 1 The firms Bribery Prevention Officer shall monitor continuously all aspects of the firms bribery prevention policies and procedures. Any deficiencies in bribery prevention compliance requiring urgent rectification will be dealt with immediately by the firms Bribery Prevention Officer, who will report such incidents to the relevant Senior Management when appropriate and request any support that may be required. The firms Bribery Prevention Officer shall conduct an annual review of the firms bribery prevention compliance, and report its findings to the firms Senior Management. This report will include: 4 a summary of the firms bribery risk profile and vulnerabilities, together with information on ways in which these are changing and evolving a summary of any changes in the regulatory environment(s) in which the firm operates a summary of bribery prevention activities within the firm, including the delivery of appropriate training details of any compliance deficiencies on which action has already been taken, together with reports of the outcomes details of any compliance deficiencies on which action needs to be taken, together with recommended actions and management support required

an outline of plans for the continuous development of the bribery prevention regime, including ongoing training and awareness raising activities for all staff. Where management action is indicated, the responsible Nicholas Day will respond to the report with details of appropriate action to be taken.

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ANNEX II - Forms

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Staff Receipt for ISAR

Dear __________________

Thank you for your Money Laundering Suspicion report. I have logged this in my files and allocated it the unique reference number. (Number that you will use for our reference)_________________________

If a transaction has been put on hold, I will instruct you how to proceed. If any further activity on the part of this client gives rise to a further suspicion of money laundering, you must submit another suspicion report. If I need any more information, I will get in touch with you.

In the meantime, please remember not to discuss your report, or the fact that you have made a report, with anyone except me. In particular, do not indicate in any way to the client that a report has been made about him or record such information in the clients file.

If other people within our organisation need to know about the report, I will let them know. If you are concerned about the report or about dealing with the client in the future, please contact me to discuss it.

Yours sincerely,

MLRO/Compliance Officer fatima.fernandes@smalworldfs.com

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AUTHORIZATION / CORPORATE CUSTOMERS

Date ___/____/____

I, n!m"er/ID , le#al representati$e of t%e

, le#al

passport entities& '%one

n!m"er

, F!ll Address& , A!t%ori(e , , passport

Mr)s* n!m"er

TO TRANSMIT MONEY ON BEHALF OF OUR TRUSTEE COMPANY TO&

Acco!nt %older name& '%one n!m"er& )C'F if ,ra(ilian*& ,an- Name& Acco!nt N!m"er& If to pa+ at Office& Cit+ DO, ,ranc%/A#enc+/ S.ift& Acco!nt t+pe& / / , Co!ntr+

I confirm t%at all t%e information #i$en is tr!e and t%at I am a.are a"o!t t%e terms and conditions of t%is proced!re&

0 T%e person .%om I %a$e a!t%ori(ed a"o$e m!st "rin# %is/%er ori#inal IDs1 ot%er.ise it .ill not "e possi"le for LCC to proceed .it% t%e transaction/ 0 I reco#ni(e t%at LCC %as no responsi"ilit+ after I si#ned t%is doc!ment a"o!t t%e information #i$en or a"o!t t%e $alidit+ of doc!ments of t%e person a!t%ori(ed a"o$e/

on

/ 23

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RISK BASED APPROACH Company Name:

Companys registration number:

Activity:

How many Directors:

How many shareholders

Beneficial owners

Subsidiaries (Including parent companies, joint venture or any other entities identified and sub companies).

Bank name and account

Payment type (cash, wire transfer, debit card, other)

How many beneficiaries: (listed in attached document)

Pay out Countries (please list which Countries you wish to send transfers)

Expected monthly transactions volumes

The large payment limit

Contact person, email and website

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