Anti Money Laundering Policy
Our AML Policy
PERFORMANCE BONUS LTD is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with Statutory Instrument No. 692 Financial Services, The Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017.
To view a complete version of these regulations, please click here.
PERFORMANCE BONUS LTD as prepaid card programme managers, works with the prepaid scheme operators and card issuers (money service businesses) with which we partner to set high standards for anti-money laundering supervision under the Money Laundering Regulations 2017.
Risk sensitive policies and procedures have been established both by our partners and ourselves in order to anticipate and prevent money laundering and terrorist financing.
The risk of money laundering and terrorist financing is minimised, by PERFORMANCE BONUS LTD prepaid card activity being restricted to only
EITHER;
order and load prepaid cards (loaded with £50 or below) in order to demonstrate card functionality to prospective new ‘corporate’ clients.
OR;
order and load at the request of our ‘corporate’ clients, from identified corporate funds as part of the incentive and reward programmes and/or corporate expense management schemes facilitated by ourselves and the programme operators and card issuers.
PERFORMANCE BONUS LTD does not market prepaid cards directly to consumers. Funds can only be loaded onto cards further to funds transfer from the corporate client’s bank account and card loading instructions from them.
It is PERFORMANCE BONUS LTD policy that all clients should undergo enhanced due diligence procedures. For corporate customers and private companies, we must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company – a search at Companies House will reveal details of directors and company secretary. The above requirements for documentation will be applied to all shareholders holding 25% or more of a business.
All corporate client organisations and their officers, in order to be accepted by our programme operator and card issuer partners before any new CO-BRAND card schemes are launched, undergo full ID validation checks by the scheme operator/card issuer to comply with card scheme issuer requirements and regulations.
Smaller organisations, wishing to use the Performance Bonus’ own brand prepaid card product must also pass KYB checks and their officers (Partners/Directors - including those signing the Application) must be confirmed as having authority to act on behalf of the company and be identified fully with a minimum of two forms of ID, evidence of identity being photographic and also evidence of residence e.g. a utility bill dated in the last three months.
Alternatively approved online money laundering checks must be made with a supplier, approved by the card issuer.
Furthermore, our prepaid card programmes are specified to comply with HMRC ‘non cash voucher’ requirements such that they may be used within PAYE Settlement Arrangements (PSA) and/or Taxed Award Scheme (TAS) arrangements. It is within our terms and conditions of business that clients correctly account for funds transmitted, establishing arrangements/reporting with HMRC as appropriate.
While PERFORMANCE BONUS LTD takes the view that most customers will not launder money, we do identify criteria that may indicate a higher risk of money laundering – e.g. where cards are only available to a very limited number of people within a business. Therefore, any such programmes will be flagged (both to the client and held on an internal register) and monitored for suspicious activity, which may result in the facility being closed and the suspicious activity being reported via the programme operator/card issuer to the authorities.
PERFORMANCE BONUS LTD is committed to staff training in anti-money laundering legislation and this is also covered as a part of the induction of all new staff as our business continues to grow.
Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism.
Suspicious Activity Reporting
A report should be made if a member of staff/ the nominated officer thinks that there is a possibility, which is more than fanciful, that a person is or has been engaged in money laundering or terrorist financing.
The report should be made to the PERFORMANCE BONUS LTD Money Laundering Reporting Officer who, should they be satisfied that there are grounds to suspect money laundering or terrorism, will escalate a Suspicious Activity Report to the appropriate officer at the scheme operator or card issuer and progress as appropriate.
Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential
Record Keeping
The following records are required to be kept for 5 years:
Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the last transaction was completed.
Supporting records relating to a customer relationship or transaction for five years from the date when the last transaction was completed.
The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.
To view a complete version of these regulations, please click here.
PERFORMANCE BONUS LTD as prepaid card programme managers, works with the prepaid scheme operators and card issuers (money service businesses) with which we partner to set high standards for anti-money laundering supervision under the Money Laundering Regulations 2017.
Risk sensitive policies and procedures have been established both by our partners and ourselves in order to anticipate and prevent money laundering and terrorist financing.
The risk of money laundering and terrorist financing is minimised, by PERFORMANCE BONUS LTD prepaid card activity being restricted to only
EITHER;
order and load prepaid cards (loaded with £50 or below) in order to demonstrate card functionality to prospective new ‘corporate’ clients.
OR;
order and load at the request of our ‘corporate’ clients, from identified corporate funds as part of the incentive and reward programmes and/or corporate expense management schemes facilitated by ourselves and the programme operators and card issuers.
PERFORMANCE BONUS LTD does not market prepaid cards directly to consumers. Funds can only be loaded onto cards further to funds transfer from the corporate client’s bank account and card loading instructions from them.
It is PERFORMANCE BONUS LTD policy that all clients should undergo enhanced due diligence procedures. For corporate customers and private companies, we must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company – a search at Companies House will reveal details of directors and company secretary. The above requirements for documentation will be applied to all shareholders holding 25% or more of a business.
All corporate client organisations and their officers, in order to be accepted by our programme operator and card issuer partners before any new CO-BRAND card schemes are launched, undergo full ID validation checks by the scheme operator/card issuer to comply with card scheme issuer requirements and regulations.
Smaller organisations, wishing to use the Performance Bonus’ own brand prepaid card product must also pass KYB checks and their officers (Partners/Directors - including those signing the Application) must be confirmed as having authority to act on behalf of the company and be identified fully with a minimum of two forms of ID, evidence of identity being photographic and also evidence of residence e.g. a utility bill dated in the last three months.
Alternatively approved online money laundering checks must be made with a supplier, approved by the card issuer.
Furthermore, our prepaid card programmes are specified to comply with HMRC ‘non cash voucher’ requirements such that they may be used within PAYE Settlement Arrangements (PSA) and/or Taxed Award Scheme (TAS) arrangements. It is within our terms and conditions of business that clients correctly account for funds transmitted, establishing arrangements/reporting with HMRC as appropriate.
While PERFORMANCE BONUS LTD takes the view that most customers will not launder money, we do identify criteria that may indicate a higher risk of money laundering – e.g. where cards are only available to a very limited number of people within a business. Therefore, any such programmes will be flagged (both to the client and held on an internal register) and monitored for suspicious activity, which may result in the facility being closed and the suspicious activity being reported via the programme operator/card issuer to the authorities.
PERFORMANCE BONUS LTD is committed to staff training in anti-money laundering legislation and this is also covered as a part of the induction of all new staff as our business continues to grow.
Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism.
Suspicious Activity Reporting
A report should be made if a member of staff/ the nominated officer thinks that there is a possibility, which is more than fanciful, that a person is or has been engaged in money laundering or terrorist financing.
The report should be made to the PERFORMANCE BONUS LTD Money Laundering Reporting Officer who, should they be satisfied that there are grounds to suspect money laundering or terrorism, will escalate a Suspicious Activity Report to the appropriate officer at the scheme operator or card issuer and progress as appropriate.
Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential
Record Keeping
The following records are required to be kept for 5 years:
Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the last transaction was completed.
Supporting records relating to a customer relationship or transaction for five years from the date when the last transaction was completed.
The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.