Damsole Technologies Limited is committed to the prevention of money laundering and terrorist financing. This policy sets out our obligations and procedures under the UK Proceeds of Crime Act 2002, the Terrorism Act 2000, and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
1. Our Commitment
Damsole Technologies Limited takes its obligations under UK anti-money laundering (AML) and counter-terrorism financing (CTF) legislation seriously. We maintain a risk-based compliance programme designed to detect, prevent, and report suspicious activity.
2. Know Your Customer (KYC) & Know Your Business (KYB)
Before any Merchant is activated on the Platform, Damsole conducts:
- Identity verification — government-issued photo ID for all beneficial owners (25%+ ownership)
- Business verification — Companies House or equivalent registration documents, VAT number, proof of address
- Sanctions screening — all applicants are screened against UK, EU, and OFAC sanctions lists
- PEP screening — Politically Exposed Persons are identified and subject to enhanced due diligence
- Adverse media screening — checks for negative news coverage related to financial crime
KYC/KYB documentation is securely retained for a minimum of 5 years from the end of the business relationship.
3. Customer Due Diligence (CDD) Levels
Standard CDD
Applied to all Merchants. Includes identity verification, business verification, and sanctions/PEP screening.
Enhanced Due Diligence (EDD)
Applied where higher risk is identified, including: Merchants in high-risk jurisdictions; Merchants processing high transaction volumes; PEPs and their associates; and complex ownership structures.
Simplified Due Diligence
May be applied where the risk of money laundering is demonstrably low, as permitted by relevant regulations.
4. Transaction Monitoring
We apply automated real-time monitoring to all transactions processed through the Platform. Our controls include:
- Velocity checks (transaction frequency and value thresholds)
- Geographic risk flags (transactions originating from high-risk jurisdictions)
- Unusual transaction pattern detection
- Large transaction alerts above defined thresholds
Alerts generated by our monitoring systems are reviewed by our compliance team within one business day.
5. Suspicious Activity Reporting
Where Damsole identifies or suspects money laundering or terrorist financing, we will file a Suspicious Activity Report (SAR) with the UK National Crime Agency (NCA) via the SAR Online portal. We will not "tip off" any party that a SAR has been filed.
All staff involved in compliance functions are trained to recognise and escalate suspicious activity.
6. Record Keeping
We retain the following records for a minimum of 5 years:
- Customer identification and verification documents
- Transaction records
- Internal and external SARs
- Staff training records
7. Staff Training
All relevant Damsole staff receive AML/CTF training upon joining and at regular intervals thereafter. Training covers recognition of suspicious activity, reporting obligations, and the consequences of non-compliance.
8. Prohibited Relationships
Damsole will not onboard or maintain relationships with:
- Shell banks or anonymous shell companies
- Merchants in sanctioned countries or territories
- Individuals or entities on UK, EU, or UN sanctions lists
- Businesses engaged in illegal activities
9. Contact
To report a compliance concern or for queries related to this policy, contact support@damsoletech.com.