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The Glasgow Law Practice Anti‐Money Laundering Policy

1. Policy Statement

It is the policy of The Glasgow Law Practice (“GLP”) to comply fully with applicable provisions of the Proceeds, of Crime Act 2002, Terrorism Act 2000 and The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and all amending legislation.

2. Purpose

2.1 The purpose of this policy is to ensure GLP’s compliance with anti‐money laundering laws and regulations, to assist law enforcement in combating illegal money laundering and to minimise the risk of GLP being used for improper purposes by having in place robust and effective procedures to implement this Policy.

2.2 By definition, money laundering is the practice of cleaning up money that has, for some reason, been obtained illegally. Often there is a complex trail involved so that the practice cannot be easily identified or traced.

2.3 Money laundering can occur in many ways. It may happen by dispersing money through many different bank accounts (to hide its origins) but can also occur when GLP is used unwittingly by clients or third parties for illegal activities.

3. Procedures

3.1 Peter Maley has been appointed as money‐laundering reporting officer (MLRO) to receive disclosures from anyone involved in GLP of any suspected money laundering activities. Robert Fitzpatrick will act as temporary MLRO if the MLRO is not available.

3.2 The MLRO will be responsible for carrying out GLP’s Anti‐Money Laundering procedures and will issue detailed guidelines to all GLP staff on procedures at regular intervals.

3.3 The MLRO will carry out at regular intervals a firm wide risk assessment based on the nature and sources of the business carried out by GLP and its client overall database and ensure that all GLP staff are carrying out appropriate Customer Due Diligence and risk based assessments of all business carried out by GLP.

3.4 The MLRO and temporary MLRO will carry out and record training provided to all staff, either in groups or on a One to One basis.

3.5 The MLRO will ensure that proper records are maintained on all the relevant activities and steps taken to deal with them, and in relation to training.

4. Customer Due Diligence

4.1 GLP should carry out procedures that help it identify customers/clients before

accepting or entering into a relationship or transaction with them.

4.2 GLP should, where applicable:

4.2.1 Identify the customer/client and verify their identity;

4.2.2 Take adequate measures to risk assess all business transacted for customer / clients;

4.2.3 Continuously monitor the situation; and

4.2.4 Maintain proper records of all checks made.

5. Policy on disclosure

5.1 If anyone knows, suspects or has reasonable grounds for thinking or suspecting that a person involved with GLP whether as a client or third party is engaged in money laundering or terrorist financing, they must report such matters to the MLRO or, if not available to the temporary MLRO immediately. The MLRO can be contacted on 0141 773 2145 / [email protected] . The temporary MLRO can be contacted on 0141 779 4466 / [email protected]

Further details on procedures for internal reporting are provided to staff in GLP internal Anti Money Laundering and Proceeds of Crime Procedures guide.

5.2 It is the policy of GLP to make disclosure to the relevant authorities if it has any cause to suspect that Money Laundering or any other crime has been committed.

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