AML Policy
Last updated: 1 January 2026
1. Our Commitment
Honest Pam Inc. is committed to the highest standards of anti-money laundering (AML) and counter-terrorist financing (CTF) compliance. We operate in full accordance with the UK Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, and the Terrorism Act 2000.
2. Know Your Customer (KYC)
All clients must complete our KYC process before accessing any services. This includes: • Identity verification for all beneficial owners and directors • Proof of address for all key individuals • Corporate documentation (certificate of incorporation, articles, register of members) • Source of funds and source of wealth documentation • Ongoing monitoring and periodic re-verification
3. Risk-Based Approach
We apply a risk-based approach to AML/CTF compliance. Clients are assessed at onboarding and assigned a risk rating (low, medium, high). Enhanced due diligence is applied to high-risk clients, including politically exposed persons (PEPs) and clients in high-risk jurisdictions.
4. Transaction Monitoring
All transactions are monitored in real time using automated screening tools. We screen against OFAC, UN, EU, and HMT sanctions lists. Unusual or suspicious transactions are escalated to our Money Laundering Reporting Officer (MLRO) for review.
5. Suspicious Activity Reporting
We are legally required to report suspicious activity to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR). We are prohibited by law from tipping off clients about any SAR filed.
6. Staff Training
All Honest Pam staff receive mandatory AML/CTF training at induction and annually thereafter. Our compliance team holds ICA and CAMS certifications.
7. MLRO Contact
Our Money Laundering Reporting Officer can be contacted at hello@honestpam.com.