Anti-Money Laundering and Sanctions Policy

1. Our role

We design and build software, including payment platforms, for businesses. We never receive, hold, transmit or settle our clients' or their customers' funds, and we are never a party to transactions processed through software we build. Clients hold their own agreements with payment providers and remain responsible for their own licences and anti-money laundering obligations.

We are not authorised or registered by the Financial Conduct Authority and are not in the regulated sector under the Money Laundering Regulations 2017. Because the software we build can be used to move money, we still apply a risk-based AML and sanctions program, and we comply with the laws that apply to every UK business, including the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Sanctions and Anti-Money Laundering Act 2018, UK export control law, the Bribery Act 2010 and the Criminal Finances Act 2017.

2. Our principles

• Know who we work with: we verify every client before signing an agreement, starting work or accepting payment.
• Risk-based approach: the depth of our checks matches the risk.
• Zero tolerance for sanctions breaches, direct or indirect.
• Lawful purpose only: we do not build tools designed to defeat financial crime controls.
• Accountability: a designated AML Compliance Officer oversees this program, which our director approves and reviews at least once a year.

3. Client due diligence

Before we sign an agreement, start work or accept any payment, we may ask for:

• the client's legal name, registration number, registered and trading addresses, and good-standing evidence;
• its directors, authorised signatories and every person who owns or controls 25% or more of it, with identity documents where our risk assessment requires;
• a description of its business, customers, markets and intended use of the software we build;
• evidence of the licences or payment-provider agreements its business requires; and
• for higher-risk clients, information on the source of the funds used to pay us.

We screen clients and their owners, directors and signatories against sanctions, politically exposed person (PEP) and adverse media lists, at onboarding and on an ongoing basis. If we cannot complete these checks, we do not proceed.

4. Enhanced due diligence

We apply enhanced checks, and require senior approval, for higher-risk relationships, including clients linked to PEPs, high-risk jurisdictions, complex ownership structures, or the restricted sectors in section 7. These may include additional documents, independent verification of licences, source of funds and wealth evidence, and more frequent reviews.

5. Sanctions and export controls

We comply with UK sanctions administered by the Office of Financial Sanctions Implementation (OFSI) and the Office of Trade Sanctions Implementation (OTSI), and with UK export controls. Where a US connection exists, such as a US dollar payment, we also comply with US sanctions and export controls. We apply UN, EU and Ukrainian sanctions where relevant. We do not provide services to, or accept payments from or for:

• any sanctioned person, or any entity owned or controlled by sanctioned persons;
• anyone located in, organised in or acting for Iran, North Korea, Cuba, Russia or Belarus, or the regions of Ukraine not under the control of the Government of Ukraine; or any project whose purpose or end use is prohibited by export control laws.

6. Prohibited business

We do not work with clients engaged in, and do not build software designed for:

• money laundering, terrorist financing, or sanctions or export control evasion;
• payment, lending, currency exchange or crypto services operated without the required licences;
• shell banks, or businesses that will not identify their owners;
• tools whose main purpose is to hide the source, destination or ownership of funds, such as crypto mixers;
• transaction laundering, misrepresenting goods or services to payment providers, or evading provider risk controls and card network monitoring;
• splitting transactions to avoid reporting or monitoring thresholds;
• forged or synthetic identities, or bypassing identity checks;
• illegal goods or services, weapons trafficking, counterfeit goods, pirated content or stolen data;
• human trafficking, sexual exploitation or child abuse material;
• pyramid, Ponzi or other fraudulent schemes; or
• unlicensed gambling.

7. Restricted sectors

We work with clients in the following sectors only after enhanced due diligence, and only where they hold the licences their business requires: banks, payment and e-money institutions, money services businesses and payment facilitators; crypto-asset businesses; licensed gambling operators; lawful adult entertainment; dealers in precious metals and high-value goods; licensed firearms businesses; and charities operating in high-risk regions.

8. Payments we accept

We accept payment only by bank transfer, or another method we approve in writing, from an account in the contracting client's own name. We do not accept cash, cash equivalents or payments from third parties without prior checks and written approval. We return overpayments and make refunds only to the account a payment came from, and we may hold or return any payment we cannot verify.

9. Ongoing monitoring

We review client relationships periodically and whenever something significant changes, such as ownership, business model, markets or the work requested. Clients must tell us promptly about changes to their ownership, management, licences or sanctions status.

10. Reporting and cooperation

Where we suspect that any payment we hold or may receive, including our own fees, is the proceeds of crime, we report to the National Crime Agency and do not deal with it unless we have the legal defence that a report provides. We freeze funds of designated persons and report to OFSI, OTSI or other authorities where the law requires or we judge it appropriate. We cooperate with lawful requests from authorities and do not disclose reports where that would be unlawful or could prejudice an investigation. Confidentiality obligations in our Terms or client agreements do not prevent these reports.

11. Refusal and termination

We may decline, pause or end any engagement, or return any payment, without giving reasons, where checks are incomplete, risk exceeds our appetite, a concern cannot be resolved, or continuing could break the law or this Policy.

12. Records, people and suppliers

We keep due diligence records for 5 years after a relationship ends, or after our decision to decline a prospect, and sanctions records for 10 years. Our team receives AML and sanctions training when joining and at least annually, and we screen our staff, contractors and key suppliers against sanctions lists.

13. Our clients' own obligations

This Policy covers BeckForge's own business. It does not replace our clients' own anti-money laundering, sanctions and fraud-prevention obligations towards their customers.

14. Contact

Questions about this Policy: partner@beckforge.co or BECKFORGE LTD, 23-27 Maidenhead Street, Hertford, SG14 1DW, United Kingdom.