AML Policy

SPOTKEYS is committed to observing the provisions of the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, the Proceeds of Crime Act 2002, Part 7 – Money Laundering Offences and the Terrorism Act 2000
(as amended by the Crime and Courts Act 2013 and the Serious Crime Act 2013) in all of its affairs, whether academic or business-related. This policy aims to ensure that SPOTKEYS and all its employees comply with the legislation and that due diligence is applied in relation to ‘know your customer’ principles.

1.2 This policy sets out the procedure to be followed if money laundering is suspected and defines the responsibility of individual employees in the process.

1.3 SPOTKEYS has a zero tolerance policy towards money laundering, and is committed to the highest level of openness, integrity and accountability, both in letter and in spirit. The penalties for these offences are severe and can mean up to 14 years imprisonment and/or an unlimited fine for the employees and executives responsible. In addition, there would be
significant reputational damage for SPOTKEYS.

1.4 This policy applies to all staff of the SPOTKEYS and its subsidiary companies and applies to all income and expenditure. Any breach of this policy will be a serious matter, may result in disciplinary action and could result in an
employee becoming personally liable to criminal prosecution.