This Policy sets out Greyline Investigations Limited's commitment to preventing money laundering, terrorist financing, and financial crime. Although private investigation firms are not currently a supervised sector under the Money Laundering Regulations 2017, Greyline adopts these procedures voluntarily as a matter of professional duty and to protect the business from being used to facilitate financial crime.
1.1 This Policy applies to all personnel of Greyline Investigations Limited, including directors, investigators, subcontractors, and any third parties acting on Greyline's behalf.
1.2 The Policy is designed to ensure that Greyline: (a) does not knowingly assist in money laundering, terrorist financing, or any form of financial crime; (b) identifies and assesses the risk of such activity in the services it provides; and (c) maintains adequate records to assist law enforcement where required.
Greyline operates with awareness of the following UK legislation:
Greyline recognises the following elevated risk indicators in its client base and case types:
Where elevated risk indicators are present, enhanced due diligence procedures apply.
4.1 Standard CDD. For all engagements, Greyline will:
4.2 Simplified CDD may be applied for repeat clients with an established and satisfactory relationship and where risk indicators are absent.
4.3 Enhanced CDD is applied where elevated risk indicators are identified.
4.4 CDD records will be retained for a minimum of five (5) years from the end of the business relationship.
Where enhanced CDD is required, Greyline will take one or more of the following additional steps:
6.1 Any member of Greyline's team who knows or suspects money laundering or terrorist financing must report this to the Nominated Officer immediately and without tipping off the suspected party.
6.2 The Nominated Officer will assess all reports and, where there is reasonable suspicion, will submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
6.3 Tipping off. Under POCA 2002, it is a criminal offence to disclose to a client or third party that a SAR has been made or that they are under suspicion.
6.4 Where a SAR has been submitted, Greyline will await NCA consent before proceeding with the relevant engagement where required by law.
Greyline will not provide services where it knows or reasonably suspects that:
Before accepting any engagement, Greyline will screen client names against the UK Consolidated List of Financial Sanctions Targets maintained by His Majesty's Treasury (OFSI). Engagements involving sanctioned individuals or entities will not be accepted. Screening records will be retained.
The following records will be retained for a minimum of five years:
The Nominated Officer (Money Laundering Reporting Officer equivalent) is the Director / Principal Investigator of Greyline Investigations Limited. All internal suspicious activity reports must be made to the Nominated Officer who has sole authority to submit SARs to the NCA.
Breach of this Policy by any personnel may result in termination of engagement and, where the breach constitutes a criminal offence, referral to the appropriate authorities. Greyline co-operates fully with law enforcement investigations.