Anti-Money Laundering Policy

Our commitment to preventing money laundering and terrorist financing.

Last updated: February 2025

1. Introduction

SHE Consulting — Success in Healthcare Education ("we", "our", "us") is committed to the highest standards of anti-money laundering (AML) compliance and to preventing the use of our services for money laundering, terrorist financing, or any other financial crime.

This policy sets out the measures we take to comply with the following UK legislation:

  • Proceeds of Crime Act 2002 (POCA)
  • Terrorism Act 2000
  • Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
  • Sanctions and Anti-Money Laundering Act 2018

2. What is Money Laundering?

Money laundering is the process by which criminally obtained money or other assets are exchanged for "clean" money or other assets with no obvious link to their criminal origins. It also covers money, however obtained, which is used to fund terrorism. Under UK law, the following constitute money laundering offences:

  • Concealing, disguising, converting, transferring, or removing criminal property from the UK (s.327 POCA)
  • Entering into or becoming concerned in an arrangement which facilitates the acquisition, retention, use, or control of criminal property (s.328 POCA)
  • Acquiring, using, or possessing criminal property (s.329 POCA)
  • Failing to disclose knowledge or suspicion of money laundering (s.330-332 POCA)
  • Tipping off a person suspected of money laundering (s.333A POCA)

3. Our Approach

SHE Consulting takes a risk-based approach to anti-money laundering. Our measures include:

3.1 Customer Due Diligence (CDD)

We conduct appropriate due diligence on clients and business partners before entering into a business relationship. This may include:

  • Verifying the identity of the client or organisation
  • Verifying the identity of beneficial owners
  • Understanding the nature and purpose of the business relationship
  • Ongoing monitoring of the business relationship

3.2 Enhanced Due Diligence (EDD)

We apply enhanced due diligence where there is a higher risk of money laundering or terrorist financing, including (but not limited to):

  • Business relationships with persons or organisations in higher-risk countries (as identified by the Financial Action Task Force)
  • Politically Exposed Persons (PEPs)
  • Complex or unusually large transactions
  • Unusual patterns of transactions that have no apparent economic or lawful purpose

3.3 Record Keeping

We maintain records of all due diligence checks and relevant transactions for a minimum of five years from the end of the business relationship or the date of the transaction, in accordance with the Money Laundering Regulations 2017.

3.4 Staff Training and Awareness

All relevant staff receive appropriate training on:

  • The law relating to money laundering and terrorist financing
  • How to recognise and deal with potential money laundering or terrorist financing activities
  • Their obligations under this policy and relevant legislation

4. Nominated Officer

SHE Consulting has appointed a Nominated Officer (also known as the Money Laundering Reporting Officer, or MLRO) who is responsible for:

  • Receiving internal reports of suspicious activity
  • Deciding whether to make a Suspicious Activity Report (SAR) to the National Crime Agency (NCA)
  • Maintaining records of all internal reports and SARs
  • Ensuring the company's AML procedures are up to date

Reports of suspicious activity should be made to the Nominated Officer promptly. Contact: admin@sheconsulting.co.uk

5. Suspicious Activity Reporting

All staff and associates are required to report any knowledge or suspicion of money laundering or terrorist financing to the Nominated Officer. It is a criminal offence to:

  • Fail to report knowledge or suspicion of money laundering
  • "Tip off" any person that a report has been made or an investigation is being, or may be, carried out
  • Prejudice any investigation into money laundering

6. Sanctions Screening

We screen clients and business partners against the following sanctions lists as appropriate:

  • HM Treasury Consolidated List of Financial Sanctions Targets
  • United Nations Security Council Consolidated List
  • EU Consolidated List (where applicable)

7. High-Risk Jurisdictions

We are alert to the risks associated with business relationships and transactions involving countries identified by the Financial Action Task Force (FATF) as having strategic deficiencies in their AML/CFT regimes. Additional due diligence measures are applied to such relationships.

8. Refusal and Termination of Business Relationships

We reserve the right to refuse to enter into a business relationship, or to terminate an existing relationship, where:

  • We are unable to carry out satisfactory customer due diligence
  • We have reason to suspect that the relationship involves money laundering or terrorist financing
  • The business relationship falls outside our risk appetite

9. Review

This policy is reviewed annually, or more frequently if required by changes in legislation, regulation, or our business activities.

10. Contact

If you have any questions about this policy, please contact us: