Financial Crime, AML & KYC Policy

1. Purpose

Aura Capital is committed to preventing financial crime, including money laundering, terrorist financing, fraud, bribery, and corruption.

While Aura Capital is not authorised or regulated by the Financial Conduct Authority (FCA), we operate in accordance with applicable UK legislation and adopt industry best practice.

This policy outlines the controls and procedures in place to identify, assess, and mitigate financial crime risk.

2. Legal & Regulatory Framework

Aura Capital’s approach is guided by relevant UK legislation, including:

- Proceeds of Crime Act 2002

- Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017

- Terrorism Act 2000

- Bribery Act 2010

We also take guidance from the Financial Conduct Authority’s financial crime framework:

https://www.fca.org.uk/firms/financial-crime

3. Risk-Based Approach

Aura Capital adopts a risk-based approach to financial crime.

We assess risk based on:

- Customer profile and background

- Source of funds and wealth

- Transaction size and structure

- Geographic exposure

- Complexity of ownership structures

Higher-risk cases are subject to enhanced due diligence.

4. Know Your Customer (KYC)

We carry out appropriate KYC checks before proceeding with any transaction.

Customer Identification includes:

- Full legal name

- Date of birth (individuals)

- Registered company details (companies)

- Residential or registered address

Verification may include:

- Government-issued identification (passport, driving licence)

- Proof of address (utility bill, bank statement)

- Electronic verification systems

For corporate entities, we identify:

- Directors

- Shareholders

- Ultimate Beneficial Owners (UBOs)

- Ownership structure

5. Customer Due Diligence (CDD)

We undertake Customer Due Diligence proportionate to the level of risk.

This includes:

- Understanding the purpose of the transaction

- Assessing the nature of the customer relationship

- Reviewing transaction rationale

- Identifying unusual or complex structures

We may request additional information where required.

6. Enhanced Due Diligence (EDD)

Enhanced Due Diligence is applied in higher-risk situations, including:

- Politically Exposed Persons (PEPs)

- High-risk jurisdictions

- Complex ownership structures

- Large or unusual transactions

EDD may include:

- Additional identity verification

- Detailed source of wealth analysis

- Independent documentation

- Senior-level approval

7. Source of Funds & Wealth

We take reasonable steps to verify:

- Source of Funds (SoF) – origin of transaction funds

- Source of Wealth (SoW) – how wealth was accumulated

Examples include:

- Property sale proceeds

- Business income or dividends

- Savings or investments

- Inheritance

Supporting evidence may be required.

8. Ongoing Monitoring

We monitor transactions and relationships for:

- Unusual activity

- Inconsistencies in information

- Changes in risk profile

Where concerns arise, we may:

- Request further information

- Pause or decline a transaction

- Escalate internally

9. Suspicious Activity & Reporting

Aura Capital takes a zero-tolerance approach to financial crime.

Where financial crime is suspected, we may:

- Request additional information or documentation

- Pause or decline a transaction

- Escalate internally

- Report the matter to relevant authorities

Reporting may be made to:

- The National Crime Agency (NCA) via a Suspicious Activity Report (SAR)

‍ ‍https://www.nationalcrimeagency.gov.uk/what-we-do/crime-threats/money-laundering-and-illicit-finance‍ ‍

- Action Fraud (UK national fraud reporting centre)

‍ ‍https://www.actionfraud.police.uk‍ ‍

- UK police forces

- International law enforcement agencies such as INTERPOL

‍ ‍https://www.interpol.int‍ ‍

- Other relevant regulatory or governmental bodies where appropriate

Where transactions involve cross-border elements, Aura Capital may cooperate with:

- International Financial Intelligence Units (FIUs)

- Overseas law enforcement agencies

- Cross-border regulatory bodies

We comply with all legal obligations, including:

- Submission of Suspicious Activity Reports where required

- Anti-money laundering legislation

- Prohibition on “tipping off” individuals

Aura Capital reserves the right to:

- Decline or withdraw from a transaction

- Halt or suspend activity

- Report concerns without notice where to comply with legal obligations or flag a transaction for suspicious behaviour

10. Sanctions & PEP Screening

We screen customers against:

- UK sanctions lists

- International sanctions databases

- Politically Exposed Persons (PEP) registers

We will not proceed with sanctioned individuals or entities.

11. Third Parties & Introducers

Where third parties are involved, we:

- Conduct appropriate due diligence

- Assess their role and credibility

- Do not rely solely on third-party checks

Ultimate responsibility for compliance remains with Aura Capital.

12. Staff Training & Awareness

All relevant staff are trained to:

- Identify financial crime risks

- Recognise suspicious activity

- Follow internal procedures

- Escalate concerns appropriately

13. Record Keeping

We maintain records of:

- Identity verification

- Due diligence checks

- Transaction details

Records are retained in line with legal and business requirements.

14. Data Protection

All personal data is handled in accordance with:

- UK GDPR

- Data Protection Act 2018

15. Refusal & Exit

Aura Capital reserves the right to:

- Decline any transaction

- Request further information

- Withdraw from a transaction

where:

- Due diligence cannot be completed

- Information is inconsistent or incomplete

- Financial crime risk is identified

- Clients become aggressive or attempt to block due diligence

- Financial crime risk is identified

16. Contact

Aura Capital

enquiries@auracapital.co.uk

01451 514563