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Anti-Money Laundering and Counter-Terrorist Financing Policy
Effective Date: July 2025
1. Purpose
Vape Venture Ltd (trading as Smoke Rings) is committed to preventing our business from being used for money laundering or terrorist financing. This policy outlines simple and proportionate steps we take to reduce the risk of financial crime, suitable for our small business of three people.
2. Legal Requirements
We follow the relevant UK laws, especially the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017, and relevant FCA and Joint Money Laundering Steering Group guidance.
3. Key Principles
We aim to:
- Check the identity of our customers where necessary.
- Refuse service to anyone on official sanctions or watchlists.
- Be alert to suspicious or unusual customer activity.
- Keep appropriate records.
- Report suspicious activity to the authorities if needed.
4. Roles and Responsibilities
As a small business:
- The Managing Director (or designated senior person) acts as the Money Laundering Reporting Officer (MLRO).
- All team members are expected to stay alert and raise any concerns with the MLRO.
5. Customer Checks
We use a risk-based approach, meaning we do more checks for higher-risk situations. Where needed, we will:
- Ask for a customer’s name, address, and date of birth.
- Verify ID using a driving licence, passport, or reliable third-party service.
- Check whether a customer is acting on behalf of someone else.
- Apply extra checks for unusual purchases or high-risk scenarios.
6. Refusing Service
We will not provide services if:
- A customer is on a sanctions list.
- We cannot verify their identity.
- They are connected to high-risk activities or jurisdictions.
- They refuse to give the information we need.
7. Monitoring and Reporting
We keep an eye out for:
- Unusual spending patterns or payment methods.
- Differences between delivery and billing details.
- Any behaviour that doesn’t seem right.
The MLRO decides whether to submit a Suspicious Activity Report (SAR) to the UK Financial Intelligence Unit (UKFIU). Records of any such reports or decisions are securely kept.
8. Record-Keeping
We keep all documents and records for five years, including identity checks, transactions, and any internal reports.
9. Training
Each team member receives basic AML/CTF training once a year, covering:
- What money laundering is.
- How to spot suspicious activity.
- What to do if something looks wrong.
10. Review
We review this policy at least once a year or if the law changes. We fix any problems as soon as they are identified.
Why choose Smoke Rings as your vape store
Free Delivery
On all orders over £25.
Same Day Dispatch
On orders placed before 2pm Mon-Sat.
Free Delivery
Within our launch week.
Smoke Rings
30 Nimbus Way
Watnall
NG16 1FP
