1

Introduction to the policy

1. 1.1

   [Firm name] is required to put in place appropriate systems and controls to combat money laundering, terrorist financing and proliferation financing under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended.

1. 1.2

   For more details on the MLR 2017, see section 10.

2

Scope and application

1. 2.1

   This policy contains the procedures we have developed to comply with the MLR 2017, as amended.

1. 2.2

   This policy applies to all [our offices, ]employees, officers, consultants, contractors and to other workers including agency workers, casual workers[, volunteers][, interns] and home workers.

1. 2.3

   All staff must be familiar with this policy and comply with its terms.

1. 2.4

   This policy does not form part of any contract of employment and we may amend it at any time.

3

Responsibility for AML, CTF and counter-proliferation financing compliance

1. 3.1

   The firm itself is primarily responsible for compliance with the MLR 2017, including all systems and control requirements.

1. 3.2

   [While the firm is primarily responsible for compliance with the