Anti-Money Laundering Policy

Policy Statement

Providence AI Ltd is dedicated to implementing robust controls to prevent money laundering and terrorist financing activities. This commitment is in line with the Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017 and subsequent amendments. Providence AI Ltd is registered with and supervised by HM Revenue & Customs for compliance with these regulations.

Managing Risk

Risk Assessment

In accordance with the Money Laundering Regulations, Providence AI Ltd conducts thorough risk assessments to understand our customers and identify potential high-risk scenarios for money laundering and terrorist financing. Based on these assessments, we have established and documented appropriate policies and procedures to mitigate these risks.

Training

Providence AI Ltd is committed to educating our staff on anti-money laundering regulations to ensure they understand the risks and legal requirements, and their responsibilities under these laws. Training is provided to all new employees and supplemented with regular updates through group sessions and communications.

Auditing

We conduct regular compliance audits to ensure adherence to our policies. All customer due diligence performed is reviewed and approved by a centralized team before any business relationship or transaction is initiated. Any required remedial actions or additional training are promptly addressed.

Customer Due Diligence (CDD) Measures

Individuals

We adhere to strict due diligence procedures to mitigate risks. This includes using advanced electronic verification tools featuring next-generation technology for identity verification.

Proof of Ownership

Ownership verification is conducted electronically as part of our standard CDD processes.

Companies and Legal Entities

For non-individual customers, such as businesses and corporations, we take necessary steps to identify beneficial owners and perform CDD on them. Documentation collected includes:

• Certificate of Incorporation for companies.
• Recent Audited Accounts.
• Information on company officers and shareholders.

Trusts and Estates

For trusts, we collect trust deeds, lists of trustees, and beneficiaries, conducting CDD on those with significant control or interest. For estates, we require documentation such as the Grant of Probate or Letters of Administration and perform CDD on executors or administrators.

Suspicious Activity Reporting

Any suspicions of money laundering or terrorist financing are to be reported to our Money Laundering Reporting Officer (MLRO) or the Deputy MLRO. They assess the situation and decide whether to file a Suspicious Activity Report (SAR) with the National Crime Agency. All such decisions are kept confidential.

Record Keeping

In compliance with legislation, we retain all records of CDD for a minimum of five years after the end of the business relationship or the completion of the transaction. This is to demonstrate compliance and assist any investigations.

Data Protection

All personal data collected for the purposes of compliance is stored securely and is not used for any other purposes. Data is kept only as long as legally required and is stored electronically on secure, cloud-based systems to minimize our carbon footprint.

Contacts

Money Laundering Reporting Officer (MLRO):

Llewellyn Lloyd
3rd Floor, 86-90 Paul Street,
London,
England,
United Kingdom,
EC2A 4NE