Anti-Money Laundering (AML) Policy

1. Introduction

People Art Ltd (the "Company") is committed to the highest standards of anti-money laundering (AML) compliance and adherence to all applicable laws and regulations in the countries in which we operate, including the United Kingdom. This policy outlines our processes to prevent and detect any activities related to money laundering, terrorist financing, and other illicit financial activities.

2. Purpose

The purpose of this AML policy is to ensure that:

People Art Ltd complies with all relevant AML regulations.

All employees and associated parties understand their responsibilities in combating money laundering.

Effective internal controls and procedures are in place to detect, report, and mitigate risks related to money laundering and financial crimes.

3. Definition of Money Laundering

Money laundering refers to the process by which individuals or organizations attempt to conceal the origins of illegally obtained money, typically through a series of transfers or commercial transactions. This illegal activity is designed to make illicit funds appear legitimate. The stages of money laundering include:

Placement: Introducing illegal proceeds into the financial system.

Layering: Concealing the illegal origin of funds by moving them through a series of complex financial transactions.

Integration: Returning the now-laundered funds to the economy in a way that they appear legitimate.

4. Responsibilities

The Company, its management, and all employees have the responsibility to:

Adhere to AML laws and regulations in the jurisdictions where the Company operates.

Report any suspicious activity in accordance with local laws and company procedures.

Ensure customers are subject to thorough due diligence and verification procedures.

Maintain appropriate records of all financial transactions and client information.

5. Know Your Customer (KYC) Policy

People Art Ltd follows strict "Know Your Customer" (KYC) procedures to verify the identity of all customers. This involves collecting and maintaining accurate information on the identities of customers, business entities, and beneficial owners. The steps include:

Identification and verification of the customer’s identity using reliable, independent documentation (e.g., passports, national ID cards, utility bills).

Monitoring ongoing transactions to ensure they align with the customer’s profile.

Performing enhanced due diligence on higher-risk customers or transactions.

6. Reporting Suspicious Activity

All employees must remain vigilant for any unusual or suspicious transactions that do not align with a customer’s known legitimate business activities. Employees are required to report any suspicious activities to the designated Money Laundering Reporting Officer (MLRO) immediately. The MLRO will then assess the activity and determine whether it should be reported to the appropriate authorities, such as the National Crime Agency (NCA) in the UK.

7. Record Keeping

The Company will maintain detailed records of all transactions, customer identification documents, and any suspicious activity reports (SARs) filed. These records will be kept for a minimum of five years, in accordance with regulatory requirements, and will be available for review by regulatory bodies upon request.

8. Employee Training

All employees, especially those involved in finance, legal, or compliance roles, will receive AML training. This will ensure they are familiar with the risks of money laundering, the Company’s procedures, and their obligations under the law.

9. Compliance Monitoring

The Company will regularly review its internal processes to ensure compliance with AML regulations. This will include:

Periodic risk assessments of customer transactions and business practices.

Regular audits of financial transactions.

Updating internal procedures to reflect any changes in AML laws and regulations.

10. Sanctions Compliance

People Art Ltd will not conduct business with individuals or entities that are subject to sanctions or are located in high-risk countries identified by international regulatory bodies, such as the United Nations, the European Union, or the Office of Foreign Assets Control (OFAC).

11. Conclusion

The fight against money laundering and financial crime is a shared responsibility. People Art Ltd is committed to doing its part by ensuring compliance with all AML regulations and fostering a culture of transparency and integrity within our business operations.

For any questions related to this AML policy, please contact our Compliance Officer at info@pplart.com.