POINT BANK is committed to the prevention of financial crime. We have assumed procedures to detect and deter money laundering, terrorist financing or other illegal activities.

It is our policy to deter and, where possible, prevent, the use of POINT BANK as a conduit for illegal money laundering activities or any other type of financial crime.

The success of this policy depends on the acuity of everyone. We have therefore looked to educate and create awareness amongst our staff in all aspects of our business.

For the effective implementation of this policy, the Financial Institution and the entire staff are:

  • Informed about the legal and regulatory framework and the legal and regulatory penalties for assisting in financial crime - even accidentally - in every jurisdiction from which we operate
  • Alert to the methods by which criminals seek to commit financial crimes
  • Aware of the need to report any suspicions promptly to the POINT BANK management


Legal and Regulatory Framework

The UK has many laws directed to preventing, detecting and reporting financial crime through money laundering or financing illegal activities.

The UK is part of The Financial Action Task Force (FATF), an inter-governmental body whose purpose is the development and promotion of policies, both at national and international levels, to combat money laundering and terrorist financing.

The FATF’s standards are applied by over 180 countries through a global network of money laundering and counter terrorist regional bodies, as well as the IMF and the World Bank.

FATF has published a series of high level recommendations which include suggested standards of customer due diligence and record keeping.

At a national level, the (Joint Money Laundering Steering Group (JMLSG) comprised of leading UK Trade Associations in the financial services industry, develops industry good practice through the publication of industry guidance. The most recent guidance is JMLSG Guidance 2007 which advocates a risk based approach to preventing financial crime. This guidance forms the basis of POINT BANK policy.

What is Money Laundering?

Money laundering refers to the process of concealing the source of legally, illegally, and grey area obtained monies.

Funding or facilitating money laundering and using laundered money are all criminal offences.

Additional offences connected with money laundering include:

  • assisting in
  • concealing
  • tipping off
  • failing to report money laundering

These offences are punishable by unlimited fines and/or imprisonment.

Guidance to Prevent Financial Crime

Warning signs of a suspicious transaction or illegal activity can include:

  • Absence of commercial justification
  • A "front individual" or "front organisation" who doesn't appear in the respective corporate structure
  • Person or transaction lacking in documentary support
  • Overly concerned about secrecy, especially regarding source of funds

Reporting Suspicions

This Joint Money Laundering Steering Group (JMLSG) guidance emphasises the responsibility of senior management in promoting an effective policy of financial crime prevention. At POINT BANK, the Money Laundering Reporting Officer ("MLRO") is a member of senior management with the specific responsibility of overseeing the implementation of our policies to prevent financial crime. The Financial Institution and each individual member of staff are required by law to report suspicious transactions, via the firm's MLRO, to the UK Serious Organised Crime Agency (SOCA). The individual obligation is satisfied by promptly reporting your suspicions to the MLRO.

POINT BANK Record Keeping Policy

At POINT BANK - All original documentation is maintained in paper or electronic format. We recognise the importance of keeping full and accurate records. All client documents are securely held within robust firewalls or premises.