Anti-Money Laundering Policy
Our framework for preventing money laundering, terrorist financing, and sanctions breaches — as required under the Money Laundering Regulations 2017 and applied to every party we transact with.
§ 01Our obligations
As a provider of services connected to business transfers, Brandex Global Ltd operates an AML programme consistent with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, subsequent amendments, and JMLSG guidance.
§ 02Customer due diligence
Before engaging any party — seller or buyer — we perform customer due diligence (CDD) proportionate to risk.
Standard CDD — all clients
- Identity verification of individuals (government photo ID + proof of address)
- Verification of corporate structure — Companies House filings, beneficial ownership registers
- Confirmation of ultimate beneficial owners (UBOs) at ≥25% ownership
- Purpose and intended nature of the transaction
- Sanctions and PEP (politically exposed person) screening
Enhanced CDD — higher-risk cases
Applied where the client is a PEP, where funds originate from a higher-risk jurisdiction, or where complex ownership structures are used to obscure beneficial ownership.
§ 03Source of funds
Buyers must evidence source of funds for the acquisition. Acceptable evidence includes recent bank statements, loan facility letters, investor capital-call documentation, or audited accounts showing retained earnings. We reserve the right to decline engagements where source of funds cannot be satisfactorily evidenced.
§ 04Ongoing monitoring
CDD is not a one-time event. We monitor transactions and relationships for unusual activity, particularly:
- Material changes to ownership or control
- Payment from third parties not previously disclosed
- Funds originating from jurisdictions inconsistent with the buyer profile
- Requests to structure transactions through opaque intermediaries
§ 05Record keeping
CDD records are retained for five years after the end of our business relationship, unless a longer retention period is required by law.
§ 06Reporting
Where we have reasonable grounds to suspect money laundering, we file a Suspicious Activity Report (SAR) with the National Crime Agency through our nominated Money Laundering Reporting Officer (MLRO). We do not "tip off" the subject of a report, as prohibited by law.
§ 07Training and governance
All Brandex personnel involved in client-facing activity complete annual AML training. Our MLRO reviews policy annually and after any material regulatory update.
§ 08Contact
For AML queries or to provide source-of-funds documentation securely, contact compliance@brandexbrokers.com.