Anti-Money Laundering (AML) & Know Your Customer (KYC) Statement

Last updated: [2025]

1. Purpose and Commitment

At LendFirst, we are committed to conducting business in full compliance with applicable UK anti-money laundering (AML) and counter-terrorist financing (CTF) laws, including:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• The Proceeds of Crime Act 2002
• The Terrorism Act 2000
• Relevant HMRC and JMLSG (Joint Money Laundering Steering Group) guidance

We take a zero-tolerance approach to financial crime and apply robust controls to prevent our products being misused for money laundering, fraud, terrorist financing, or other unlawful activities.

2. Customer Due Diligence (CDD)

Before establishing any business relationship or completing any transaction, we carry out KYC checks to verify the identity of our customers, their representatives, and ultimate beneficial owners.

These checks include (but are not limited to):

• Valid proof of identity (e.g. passport, photo driving licence)
• Proof of address (e.g. utility bill, bank statement dated within 3 months)
• For companies: incorporation documents, registers of directors/shareholders, and confirmation of beneficial ownership
• For trusts: trust deeds and details of trustees, settlors, and beneficiaries
• Source of funds and wealth declarations supported by evidence

Enhanced Due Diligence (EDD) will be conducted where higher risks are identified (e.g. politically exposed persons, high-risk jurisdictions, or complex structures).

3. Ongoing Monitoring

We continuously monitor transactions and customer relationships to detect and prevent suspicious activity. Monitoring includes:

• Reviewing transactions against expected behaviour and known risk profiles
• Screening against international sanctions, watchlists, and politically exposed persons (PEP) lists
• Reviewing and updating KYC records periodically or when a material change occurs

4. Record Keeping

In line with UK legislation, we retain copies of identification documents, due diligence records, and transaction data for a minimum of 5 years from the end of the relationship or date of the transaction.

5. Reporting Obligations

We are legally required to report any knowledge or suspicion of money laundering or terrorist financing to the National Crime Agency (NCA) through a Suspicious Activity Report (SAR).

• Staff are trained to identify and escalate red flags.
• We cannot inform a customer if a SAR has been made (this is a criminal offence known as “tipping off”).

6. Training & Culture

All employees and relevant third parties receive mandatory AML/KYC training on:

• Legal and regulatory obligations
• Identification of suspicious activity
• Proper customer due diligence procedures
• Internal escalation and reporting lines

Training is refreshed regularly to reflect evolving risks, typologies, and regulatory changes.

7. Responsibilities

The LendFirst Compliance Officer / MLRO (Money Laundering Reporting Officer) is responsible for:

• Oversight of AML/KYC policies and procedures
• Approving high-risk relationships
• Receiving and escalating internal suspicious activity reports
• Acting as the primary point of contact with regulators and law enforcement

8. Statement for Clients & Brokers

• We may request additional documents or information to satisfy our AML/KYC obligations.
• We cannot proceed with funding until these checks are complete.
• Failure to provide adequate information may result in delays, refusal of finance, or termination of our relationship.
• By applying for a loan or introducing a borrower, you agree to cooperate fully with our AML/KYC requirements.

9. Continuous Improvement

We review and update our AML/KYC framework regularly to ensure it remains aligned with legal requirements, best practice standards, and evolving financial crime risks.

Contact for AML/KYC queries:
Compliance Department – LendFirst Ltd
Email: compliance@lendfirst.co.uk