Anti-Money Laundering Policy

• Effective Date

  June 4, 2025

• Last Update

  June 5, 2025

Call Fix Ltd ("the Company") is committed to preventing its services from being used for money laundering or terrorist financing. While we operate in a low-risk industry, we recognise the importance of vigilance and sound procedures to detect and report suspicious activity.

This policy is designed to ensure compliance with applicable laws and regulations in the United Kingdom, including:

• The Proceeds of Crime Act 2002 (POCA)

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)

• The Terrorism Act 2000

Scope

This policy applies to all employees, contractors, and agents of Call Fix Ltd. It covers all services offered, payments received, and interactions with customers and third-party vendors.

Responsibilities

The Company has appointed a designated Money Laundering Reporting Officer (MLRO) to oversee compliance with this policy. The MLRO is responsible for:

• Receiving and assessing internal reports of suspicious activity

• Making Suspicious Activity Reports (SARs) to the National Crime Agency (NCA)

• Ensuring staff awareness and training

• Keeping records of all AML-related activity

Customer Due Diligence (CDD)

Although we typically serve individuals and businesses for one-off transactions, we will apply reasonable due diligence measures when:

• A customer requests a large, unusual transaction or multiple transactions

• There is reason to doubt the legitimacy of the payment method or source of funds

• There are inconsistencies or suspicious behaviour in communication

CDD measures may include:

• Verifying the identity of the customer (e.g., name, address, and contact information)

• Confirming the source of funds when appropriate

• Recording all relevant details of the transaction

Enhanced due diligence will be considered for higher-risk scenarios, such as international payments from high-risk jurisdictions.

Acceptable Payment Methods

To minimise AML risks, Call Fix Ltd accepts payment through secure and traceable methods only, such as UK-issued debit or credit cards.

Monitoring and Recordkeeping

All transactions and customer communications are monitored and retained in accordance with applicable legal requirements. The Company maintains:

• Invoices and receipts

• Customer contact logs

• Suspicious Activity Reports (if any)

• Evidence of due diligence checks

Records will be stored securely and retained for a minimum of five years.

Suspicious Activity

Staff must report any suspicious transactions or behaviour immediately to the MLRO. Examples of suspicious activity may include:

• Attempts to pay large sums in cash

• Refusal to provide identification or relevant details

• Unusual or inconsistent communication

• Requests to split payments across multiple cards or accounts

The MLRO will evaluate the report and determine whether a SAR should be submitted to the NCA.

Staff Training

All staff involved in taking bookings, processing payments, or handling customer data will receive basic AML awareness training. Training will be refreshed annually and recorded as part of ongoing compliance.

Reporting Obligations

If a SAR is required, the MLRO will submit it to the National Crime Agency using the appropriate procedures. Staff must not inform the customer (this would constitute tipping off, which is a criminal offence).

Policy Review

This AML Policy is reviewed annually, or sooner if legal or regulatory changes require. Updates will be communicated to all staff and incorporated into ongoing training.