Anti Money Laundering Policy

This is a Prince’s Trust policy that applies to staff and volunteers working on the Enterprise Programme

Policy Statement

The Trust’s purpose is to help disadvantaged young people to get into work, education, training or volunteering. One of the routes to work is through self-employment, which The Trust offers through the Enterprise programme. This initiative provides training, advice and unsecured loan finance to young people who wish to start up in business.

As The Trust provides unsecured loans, it is a regulated business for the purposes of the Money Laundering Regulations 2007. This legislation sits alongside the Proceeds of Crime Act 2002 and the Terrorism Act 2000. The Trust’s regulator is The Office of Fair Trading (OFT), which provides guidance on the legislation. The Trust has followed this guidance to produce this policy and associated guidance on what staff and volunteers need to do. The guidance is published on the Enterprise programme page of Trustnet.

Risk Assessment

The Trust only makes loans to those young people who complete the Enterprise Programme and who qualify for funding following reviews of credit scores and outstanding debt commitments. Average loans are small and are usually in the region of £2,500. The Trust does not provide expansion loans. Each young person is allocated a mentor, with whom they maintain regular contact until the loan is repaid. Given the small sums loaned and on-going liaison with The Trust, the Senior Management Team has agreed that the risk of money laundering by beneficiaries on the Enterprise programme is low. The Trust needs to provide support to staff to ensure they know what they need to do.

Advice, Guidance and Support for staff is provided in three ways:

a) Procedures

The procedures are very simple to follow. They are contained in the Anti Money Laundering Guidance (set out below) and simply refer to the identification checks for all potential recipients of loans and “things to look out for” whilst a loan is being repaid.

b) Briefing

Briefing and annual updates will be provided to everyone working on the Enterprise Programme. This will also be provided as part of induction for new volunteers and staff.

c) Money Laundering Reporting Officer (MLRO)

The Secretary to The Prince’s Trust is the MLRO. The MLRO is available to help answer any questions about money laundering issues and to report any suspicions on behalf of The Trust. Further information on the role of the MLRO can be found in the guidance.

Anti-Money Laundering Guidance

The Prince’s Trust is required to comply with Anti-Money Laundering legislation. All those involved in the payment or processing of loan repayments or who mentor young businesses should be aware of their obligation in law to comply with this guidance. For further information, please contact the Secretary.

Pre-Loan Identification Checks

All young people applying for financial support must undergo application checks before they receive loan funding from The Trust. Specifically, this means providing evidence of full name, residential address and date of birth.

What Do We Need To See?

The Trust would normally expect to see a government issued document with the young person's full name and photo with either the young person's date of birth or residential address, such as

  • Valid passport or photocard driving licence
  • Identity card issued by the Electoral Office for Northern Ireland

OR

  • a government issued document without a photo which has the young person's full name and supported by secondary evidence showing the young person's address, such as an old style driving licence;
  • recent evidence of entitlement to state or local authority-funded benefit such as housing benefit or council tax benefit.

AND

  • a utility bill, bank statement or credit union statement dated within the last three months.

AND

  • one original proof of a business bank account, for example a voided cheque or letter from the bank;

In addition, the documents should also be checked to ensure the young person:

  • Is aged 18-30 and lives in England, Wales or Northern Ireland;
  • If they are a non-EU national, that they have valid visa documentation;
  • If they are a refugee, that they have 'leave to remain' documentation.

These documents should be checked to ensure they are valid and that there are no inconsistencies. Records must be kept for five years after the loan had been repaid.

How would you know if something might be wrong?

For new applications, if

  • checking identity is more difficult than usual;
  • the documents supplied appear to be forged;
  • the young person is very reluctant to provide details of identity;
  • the young person requests payment to an apparently unconnected third party; or
  • the young person is unconvincing in their desire to start a business.

In cases like this, please contact the Money Laundering Reporting Officer (MLRO) at Park Square East. The MLRO is Nicola Brentnall, who can be contacted at nicola.brentnall@princes-trust.org.uk or 0207 543 7480. No further progress should be made with the loan application until consent is received to proceed.

For existing businesses, if

  • A transaction is different, in terms of size or frequency, from the normal business of the young person without clear reason;
  • money is paid by a third party who does not appear to be connected to the young person;
  • a cash transaction is unusually large and the young person will not disclose the source of the funds.

Other suspicious activity

  • There has been a significant or unexpected improvement in the customer’s financial position and they are unable to give a proper explanation of the source of these funds.

Once in receipt of a report, The MLRO will decide whether the police need to be informed. In the meantime, any other contact from the young person should be notified to the MLRO, who will advise on next steps following receipt of response from the police. The police usually respond within seven days.

Where reports have been filed, it is advised that no proactive contact is made with the business until the “all clear” has been given to avoid the risk of tipping off.

Tipping Off

Nothing should be done that may ‘tip off’ a third party that disclosure has been made or might be made to the police, as this might prejudice any investigation that might follow.

The MLRO will keep records of internal and external report decisions.