Motion Workforce Solutions
Governance

Anti-Money Laundering Policy

Motion Workforce Solutions Ltd does not knowingly enter into or support arrangements involving the proceeds of crime, terrorist financing, sanctions evasion, fraud or other financial crime. This policy sets out the controls applied to clients, suppliers and business transactions.

1. Scope and legal context

This policy applies to directors, employees, contractors and persons acting for the company. Workforce and payroll support is not, by itself, a sector required to register for AML supervision under the Money Laundering Regulations 2017. We will assess any new activity and obtain advice or registration before carrying on regulated work. The company remains subject to generally applicable law, including the Proceeds of Crime Act 2002, Terrorism Act 2000, sanctions legislation and fraud offences.

2. Risk-based due diligence

  • confirm the identity, legal status, ownership and business activity of prospective clients and material suppliers
  • understand the purpose, expected scope and payment arrangements of the relationship
  • identify beneficial owners and persons authorised to instruct or approve payments where proportionate
  • carry out enhanced checks where ownership is unclear, activity is unusually complex, jurisdictions present increased risk or a politically exposed person is involved
  • screen relevant parties against applicable UK sanctions information where the risk requires

3. Payment controls

  • use traceable business payment methods and verified account details
  • investigate material changes to bank details or payment instructions before acting
  • do not accept or make unexplained third-party payments
  • do not accept large cash payments
  • reconcile payroll and supplier payment instructions against approved records

4. Warning signs

Concerns may include reluctance to identify owners, unexplained urgency, unusual payment routes, false or inconsistent documents, transactions without a clear commercial purpose, links to sanctioned persons or jurisdictions, or instructions designed to conceal the source or destination of funds.

5. Escalation and reporting

A person who knows or suspects financial crime must stop where safe to do so, preserve relevant records and report the matter promptly to a director. The company will obtain specialist advice and make a report to the National Crime Agency or another authority where legally required. No person may disclose information in a way that could prejudice an investigation or amount to tipping off.

6. Records and training

Due diligence, approvals, risk decisions and reports are retained securely for the period required by law, contract and the company’s retention schedule. Relevant personnel receive instruction appropriate to their responsibilities and the risks they may encounter.

7. Breach

A breach may result in removal from an assignment, termination of contract, disciplinary action and referral to law enforcement or a regulator. Questions or confidential reports may be sent to info@motionworkforcesolutions.com.