AML training pack 2024

1. Anti Money Laundering (AML) and Counter Terrorism Financing (CTF)

Corporate Services 2024
Click here to
begin

2. Introduction to

Anti Money Laundering (AML) & Counter Terrorist Financing
(CTF)
• The training pack can take 45-60 minutes to complete.
• Press
icon to progress to the next page.
• Management are required to complete additional training via
icons.
• Upon completion of the training, you will complete an Anti-Money
Laundering questionnaire.
• If you have any further questions following the training pack, do
not hesitate to contact; compliance@poferries.com.
Corporate Services - P&O Ferries Holdings Limited 2024
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3. Training Objectives

Your training objectives:
• You will understand relevant law and regulations relating to
Anti-Money Laundering (AML) as per HMRC (His Majesty’s
Revenue and Customs).
Click icon for
management
considerations
Corporate Services - P&O Ferries Holdings Limited 2024
You will understand the correct Processes and Procedures to
follow, and to ensure how you can operate and abide within the
law.
You will learn how to record Large transactions and to be able
to identify / report suspicious transactions.
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4. Training Objectives 

The Government Objective
“To promote a robust and
competitive Money Services
Business (MSB) sector that is
properly protected from the risk
of money laundering and
terrorist financing purposes”.
The MSB Sector comprises of: Money Transmitters, Bureau de Changes, Cheque
Cashers.
The government aims to ensure that the MSB sector is both highly competitive and
properly safeguarded from abuse from money laundering and terrorist finance
purposes.
They provide comprehensive guidance on the legal requirements to deter, detect and
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disrupt money laundering and terrorist financing.
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5. The Government Objective

P&O Anti Money Laundering Policy
P&O is committed to carrying out its business in a fair, honest, and open manner. As such we have
adopted a risk-based approach to the application of measures to prevent money laundering and
terrorist financing.
Embracing CATCH ensures that P&O delivers against expectations:
Controlling the business
Appointing MLRO
Train Staff
Confirm identity of our customers
Hold all records for a minimum of 5 years
Anti-Money Laundering
Policy.
Click Icon to view full
policy
The Company have in place a Compliance team to renew, enforce and maintain company policies,
which include Anti-Money Laundering, Counter Terrorism Financing and Sanctions.
P&O ferries appointed Money Laundering Reporting Officer (MLRO) is Amelia Mitchell.
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6. P&O Anti Money Laundering Policy

Money Laundering
Fraud
‘Money laundering’ is a term used when money has
been obtained in a deceitful manner, which is
then passed off, or exchanged for ‘clean money’.
These are all criminal acts and the proceeds from
these criminal acts is known as ‘criminal property’.
Money obtained in a deceitful manner can range from
things such as;
Theft
Forgery
Tax Evasion
Bank Robbery
The Sale of Drugs
Sale of stolen goods.
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7. Money Laundering

Terrorist Financing
Money laundering can also
relate to funding terrorists, this
is called Terrorism Financing;
therefore, it is vital that we
abide by the guidelines.
Concealing, disguising,
converting, transferring
or removing (from the
jurisdiction) criminal
property
Criminal Offences that apply to
money laundering and
Terrorist Financing:
Acquisition, Possession
or use of proceeds of
criminal activity.
Corporate Services - P&O Ferries Holdings Limited 2024
Making arrangements
that aid the acquisition,
retention, use of control
of criminal property by
or on behalf of another
person.
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8. Terrorist Financing

HOW IS THE MONEY CLEANED
Criminals want to make money obtained by their crime ‘clean’, so there are
no longer any links to the crime itself.
They will do this in a variety of ways. It could be by making a large purchase
such as buying a car or exchanging a large amount of currency into another
currency.
When illicit cash is involved, criminals may use MSBs to move money out of
their hands into the financial system. The services provided by MSBs can
also be attractive to those financing terrorism, who exploit the same
vulnerabilities.
It is important to note that any profit or
gain obtained from any criminal offence,
if committed in the UK, will also be
covered by these guidelines.
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9. HOW IS THE MONEY CLEANED

LAWS AND
REGULATIONS
What will we learn?
Primary and Secondary Law
Why do laws and regulations apply to
P&O?
How could you commit an offence?
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10. LAWS AND REGULATIONS

WHY DO LAWS AND
REGULATIONS APPLY TO P&O?
P&O is registered with HMRC as a money service business, and this covers all our foreign exchange
bureaus. As we are a Money Services Business, we must abide by the regulations laid down by
HMRC.
People refer to money laundering laws and regulations as ‘Anti Money Laundering’ (AML)
guidelines. These regulations are laid down by HMRC to ensure that we (P&O) do not assist
anyone in laundering money, there are serious penalties for organisations or individual
members of staff who do not abide by the guidelines.
These laws and regulations deal with both the suspicion of
money laundering and terrorist financing. These Acts cover not
only the proceeds from crime but all funds regardless of their
origin.
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management
considerations
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11. WHY DO LAWS AND REGULATIONS APPLY TO P&O?

PRIMARY LAW
There are several Primary Laws that apply to Money Service Businesses like us to combat Money Laundering. Under
certain acts we are obliged as a business to report where there are reasonable grounds to know or suspect
offences relating to money laundering or terrorist financing.
Click each
icon to reveal a Primary Law that apply to our MSB;
The Proceeds of
Crime Act 2002
(POCA)
Terrorist AssetFreezing etc. Act
2010
The Terrorism Act 2000
(TA 2000) & CounterTerrorism Act 2008
The Anti-Terrorism,
Crime and Security
Act 2001
Criminal Finances
Act 2017
The Payments
Regulation (EU)
2015/847
Access the Money Laundering
manual to understand the Laws
in depth.
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12. LAWS AND REGULATIONS

SECONDARY LAW
The secondary law on money laundering is contained in the “Money Laundering, Terrorist Financing and Transfer of
Funds (Information on the Payer) Regulations 2017 (MLR 2017)”.
The law sets out the additional obligations of private sector firms (such as MSB) in areas of high money laundering
risk. Our Company and foreign exchange bureaus must comply with the following:
Notification and registration requirements
Customer due diligence
Ongoing monitoring of business relationships
Record keeping
Policies and procedures to prevent money laundering
Appoint a nominated officer – P&O Money Laundering Reporting Officer is Amelia Mitchell
Training of employees
MLR 2017 aims to stop criminals using professional services to launder money by requiring MSB’s to take a riskbased approach.
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13. PRIMARY LAW

Anti Money Laundering
Offences
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management
considerations
Failure to disclose, whether you know or suspect or have reasonable grounds for
knowing or suspecting that another person is engaged in money laundering or
terrorist funding activity.
Tipping-off any person that a disclosure has been made, knowing or suspecting that
doing so is likely to prejudice an enquiry.
Wilfully turning a blind eye.
Failure to adequately ascertain the facts.
Knowingly or un-knowingly Tipping-Off the customer.
Failure to make adequate enquiries (Know Your Customer – KYC) and due diligence
to assure yourself of the legitimacy of a transaction.
Carrying out a transaction with someone on the Sanctions list.
Not completing KYC requirements for large transactions
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14. The Terrorism Act 2000 & Counter Terrorism Act 2008

WHAT IS ‘TIPPING OFF’?
‘Tipping off’ - Revealing to the customer that any suspicion of money laundering or terrorist
funding has been made or that an investigation is being carried out.
A ‘Tip-off’ may take many different forms; It can also take place ‘unknowingly’ by the actions of
the cashier (for example, by taking too long over the transaction, being nervous or lacking
confidence)
This could also be seen as informing the customer of the companies Identity thresholds, that you
are completing a SAR, or have completed one.
Conviction for this offence can incur up to 2 years’ imprisonment and or/an unlimited fine
A regulated business must not tell a customer that:
• Details of their transactions or activities will be/have been reported to relevant authorities
• They are being investigated by law enforcement.
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15.

FINANCIAL
SANCTIONS
What will we learn?
Where they come from and who sets them.
What a Sanction is.
What the consequences are of serving someone on the list.
Where can you find the Sanctions list?
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16. Terrorist Asset-Freezing etc. Act 2010

WHAT IS A SANCTION?
Sanctions are Political trade tools, mainly put in place against target countries with the aim of
maintaining or restoring International peace and security.
Their Principal purpose is usually to change the behaviour of a target countries regimes,
individuals or groups in a direction which will improve the situation in that country.
The ultimate objective of a Sanction varies according to the situation, for example; an arms
embargo and a ban on export of certain items or raw materials, could be aimed at supporting a
peace process or restricting the financing of weapons.
Financial sanctions prohibit firms carrying out transactions with a person or organisation known
as a target, in some cases the order will prohibit a firm from providing any financial services to
the target.
P&O Sanctions Policy
click icon to view
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17. The Anti-Terrorism, Crime and Security Act 2001]

INTERNATIONAL FINANCIAL
SANCTIONS
Financial sanctions can be imposed against certain individuals and countries to prevent terrorist
funding from any financial services.
Financial sanctions used by P&O and our vessels come from OFSI Sanctions list, this is a consolidated
list.
P&O is committed to zero tolerance of any form of ‘Sanction Enabling’ that is carried out by its
employees, consultants, contractors, agents and any other persons that are associated with it.
(a)Any Company employee found to be in breach of the Sanctions policy shall be disciplined in
accordance with the Disciplinary Policy.
(b)Breaches of financial sanctions are a serious criminal offence. The level of penalties for breaches
of financial sanctions have been expanded and, for custodial sentences, uplifted by the Policing
and Crime Act 2017.
Click the icon to view current UK
sanctions
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18. The Payments Regulation (EU) 2015/847 

RISK BASED
APPROACH
What will we learn?
What is Risk based approach.
What is a PEP?
High Risk Countries.
Thresholds - When do we need to ask for ID
Know your Customer – KYC
Types of Primary and Secondary ID.
What to check for within the ID given.
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19. Criminal Finances Act 2017

WHAT IS A RISK BASED
APPROACH?
A risk-based approach to anti-money laundering (AML) facilitates a proactive
approach designed to identify and assess relevant risks before completing
transactions.
Therefore, P&O Ferries embrace a Proactive approach rather than a Reactive
one.
Risk assessment:
For each client we need to identify the money laundering risk that they pose.
The client should be categorised, low (i.e., small amounts of cash), medium (i.e.,
unwilling to answer questions) or high risk (i.e., over the ID Threshold or
fraudulent notes).
It is this risk categorisation which determines which level of due diligence
should be completed.
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20. SECONDARY LAW

HOW WE APPLY A RISK BASED
APPROACH
We need to establish the risk level before carrying out transactions with the
customer.
• You will need to look at what the transaction type is? - Type of currency
requested, is it relevant to our sailing route? Does it match their given
destination?
• Speak with the customer asking simple questions about their destination or
where they are coming from – Are the answers plausible?
• Look at the money that is handed over- Is it a large amount and in larger
denominations?
• You may wish to check the passport for nationality – Does their identification link
with a high-risk country?
• What reason does the passenger have for making the transaction? Ask follow up
questions, are there any discrepancies in the answers given.
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21. Anti Money Laundering Offences

HIGH RISK COUNTRIES.
A “High Risk Country" are those countries that have significant deficiencies in their regimes to
counter money laundering and terrorist financing.
These countries are identified by the Financial Action Task Force (FATF) and the UK align
themselves with their list.
Under the UK’s Money Laundering Regulations (regulation 33(1)(b)), P&O are obliged to carry
out customer due diligence and enhanced ongoing monitoring on all customers from high-risk
third countries as listed in schedule 3ZA.
Some high-risk countries may have further financial sanctions measures in place, for example
Syria, Iran and Yemen all have additional sanctions in place.
Further details on high-risk countries can
be found in the P&O Sanctions Policy - click
icon to view
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22. ANTI MONEY LAUNDERING OFFENCES

WHEN IS IDENTIFICATION
REQUIRED?
Any transactions of €2,000+ request Primary ID
Any transactions of €5,000+ request Secondary ID as well as Primary ID.
Do not carry out any transactions of €9,500+ (or currency equivalent).
Carrying out a linked transaction – where a customer may return to the bureau and ask for an
additional transaction to try to avoid the ID threshold –request Primary ID. (This is known as ‘Smurfing’
Any transaction where the cashier is suspicious after using Risk based approach to transaction.
Request Primary ID
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23. WHAT IS ‘TIPPING OFF’?

POLITICALLY EXPOSED
PERSONS (PEPs)
Politically exposed persons (PEPs) are subject to enhanced due diligence when accessing
financial institutions because they are more vulnerable to corruption.
PEPs can be defined as “Individuals entrusted with prominent functions”.
This can be, but not limited to:
Government Officials
Politicians
Military Leaders
Senior executives (Private and Public organisations)
A relative or a known close associate of a PEP (also referred to as RCAS).
In the United Kingdom, all PEPs are subject to additional due diligence.
Further details can be found in
the AML manual.
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24. FINANCIAL SANCTIONS

KYC – KNOW YOUR CUSTOMER
It is important for us to know our customers and the source of their funds. The purpose of this is to reduce
the risk of P&O being used for money laundering.
It is important to gather information about our customers during every transaction to assess if there is a
higher risk than initially foreseen.
Some Questions to try asking the customer:
1. Are you doing anything special when you arrive at your destination?
2. Why did you choose to do your transaction with us today (Was it the exchange rates)?
3. Will we see you again? (is this going to be a regular large deal)
4. What are you using this money for? (Larger transactions)
Additional Questions for Freight customers:
5. What company do you work for?
6. Can you provide an email address for the company?
It is important to gather information about our customers in addition to the required Identification (ID)
details.
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25. WHAT IS A SANCTION?

KYC – THRESHOLD / HIGHER
RISK
NOTE – Once email is sent to compliance the copy of ID must be
destroyed onboard and removed from the email system.
Transactions over €2000
is classed as Higher
risk in comparison to
lower-level transactions
(i.e. £100) and therefore
more questions and
details are required.
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Details you *Must record
for KYC, plus additional
details to ask for:
*Full Name
*Date Of Birth
*Reason for Transaction
*ID details
*Address
*Journey/Transaction
Details
*Nationality
Phone Number
Email Address
Employer Details
Remember to ask for as
many additional details as
possible – Freight Drivers
Company Name, Email
address, Journey Details
(destination, business or
pleasure), Reason for
large transaction.
Any transaction of
€2,000+ (or currency
equivalent) must be
reported as soon as
possible once the
transaction is complete,
this is done via an email
to the compliance team.
This should include a
copy of the ID taken.
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26. INTERNATIONAL FINANCIAL SANCTIONS

CUSTOMER DUE DILIGENCE
(CDD)
Customer due diligence (CDD) is the process of identifying your clients and
checking they are who they say they are.
Criminals often seek to mask their true identity – for example, by using complex
ownership structures. The purpose of CDD is to know and understand a client’s
identity and business activities so that any ML risks can be properly managed.
All customer due diligence and enhanced due diligence (EDD) profiles are
completed by the compliance team and on occasion cashiers may be asked to
obtain additional information from the customer.
Extra Checks are carried out by means of reviewing companies house, open
source and adverse media for CDD. In addition, High-risk and High-value
customers are required to provide source of the funds for EDD checks.
All Enhanced Due Diligence checks are required once customers have carried out
transactions totalling over the €9,500 threshold. Be aware following an EDD
check, the compliance team may contact yourself to aid in preventing any further
transactions being carried out by an individual.
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27. RISK BASED APPROACH

ANTI MONEY LAUNDERING (AML)
vs KNOW YOUR CUSTOMER (KYC)
What is the Difference?
Know your customer (KYC) is the process of determining the identity of the customer, this
can be an individual or a business. You need to check; is this genuine? can you trust this
individual or organisation?
KYC forms part of our AML procedure and should be carried out in conjunction with
each other during the same process.
KYC is the identity verification and risk management aspect of a client business
relationship. AML is seen as a wider process involving transaction monitoring and
sanctions.
Background
Check
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4 steps of AML -
Continuous
Monitoring
Risk Based
Approach
Identity
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28. WHAT IS A RISK BASED APPROACH?

PRIMARY FORMS OF
IDENTIFICATION
Passport
Driving Licence
National Identity Card
NB the Primary ID must have a photograph of the holder.
For Passports and National ID cards the country of origin
(issuing authority) must be noted as well as the number.
For example – Italian ID card number 12345678 – Belgian
passport No 12345678. The name, address and date of
birth must also be documented.
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29. HOW WE APPLY A RISK BASED APPROACH

SECONDARY FORMS OF
IDENTIFICATION
Secondary ID should always cross reference and validate Primary ID.
Driving License – This cannot be used as both Primary and Secondary ID.
Bank Statement (Within last 3 months) - Statements must show the person's
name and address.
Domestic Utility Bill - Domestic bills must show the name and address
Electricit
y
Gas
Council
Tax
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Insuranc
e
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30. HIGH RISK COUNTRIES.

What to look for When checking
Customer ID
Check the document for
validity – Quality of
paper/plastic. Could it be
fake?
Has it been tampered with?
Any pages torn from passport
etc.
Check the photograph for
likeness of the customer.
Check the customers
signature – does Primary and
secondary match (if
necessary).
Check the spelling of names –
are they consistent?
Check the DOB – keep the DOB
as a reference as well as
considering does the customer
look the right age?
If there is an expiry date the
document should only be
accepted as evidence if still in
date.
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Ensure any bills or statements
are within the last 3 months.
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management
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31. WHEN IS IDENTIFICATION REQUIRED?

SUSPICIOUS
TRANSACTIONS
What will we learn?
What Suspicious Transactions are.
Red Flags to consider.
How to report suspicious transactions.
How to avoid committing an offence.
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32. POLITICALLY EXPOSED PERSONS (PEPs)

WHAT IS A SUSPICIOUS
TRANSACTION?
• A suspicious transaction is one where there is some evidence or some circumstances to
reasonably suggest that a person may be laundering money. Any activity which does not fit in
with our normal type of trading could be regarded as suspicious.
• A ‘gut’ feeling is not enough to raise a suspicious transaction report but often people call it a
‘gut’ feeling because they cannot clearly identify what is wrong with a customer's
behaviour……..
• Always get as much information as you can from the customer before rejecting the
transaction. If the customer is reluctant to provide any information to you and they think you
might carry out the transaction, you might get some important information. As soon as they
realise you are rejecting the transaction, they will lose interest and walk away..
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33. KYC – KNOW YOUR CUSTOMER

KEY INDICATORS OF
SUSPICIOUS TRANSACTIONS
RED FLAGS
Checking the customers
identity proves difficult.
Customer is reluctant to
provide Identification.
Customer tries to avoid
answering your questions.
Customer tries to
exchange a large amount
of cash without prior
notice.
Customer is using cash in
large denomination notes
to carry out a large
transaction.
Customer requests the
currency exchange in the
large denomination notes.
Customer refuses to
say/disclose source of the
funds.
Large transactions carried
out in haste.
A large transaction where
the customer is not
bothered about
discounted rates and
accepts the tourist rates.
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Several transactions
carried out below the
threshold for ID.
A customer in a hurry and
agitated.
Remember If you think its suspicious in any way report it!
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34. KYC – THRESHOLD / HIGHER RISK

HOW TO REPORT SUSPICIOUS
TRANSACTIONS
Try to get as many details
as possible from the
customer, passport
information etc.
Avoid Tipping off
customer.
Notify your Line
Manager.
If you have any doubts
consult the AML Manual
or your line manager.
The SAR report is sent
directly to the Compliance
team to investigate, and
they will inform the MLRO
Complete a SAR form as
soon as possible with as
much detail available.
You must submit a Suspicious Activity Report (SAR) when you know, suspect or
have reasonable grounds to suspect that you may have encountered any proceeds
of crime or that someone is engaged in money laundering or dealing in criminal
property.
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35. CUSTOMER DUE DILIGENCE (CDD)

SUSPICIOUS ACTIVITY REPORT
(SAR) FORM
SAR is another term used for suspicious transaction report.
Ensure you familiarise yourself with the SAR Form and what details
are required.
Take a look, and complete a SAR form to see how it looks,
then you’re ready for when you need it.
Please ensure you state the reason as “TEST” form.
code
Click here to open or use the QR
Click icon for
management
considerations
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36. ANTI MONEY LAUNDERING (AML) vs KNOW YOUR CUSTOMER (KYC)

SUSPICIOUS TRANSACTIONS
MANAGEMENT CONSIDERATIONS
The regulations for AML have evolved over a number of years now and they will continue to
evolve and become more robust
It is not possible to completely eliminate the risk of money laundering, but we can ensure that by
following the guidelines the risks are minimised
If you have any concerns or issues with anything that may be related to this training, please
contact the compliance team.
No one will criticise you for being careful. Reporting transactions as suspicious which later turns
out not to be, is not a crime.
The biggest issue that could face P&O is not only the fines or sanctions that could be imposed by
HMRC but the fact that huge damage could be done to the much-trusted P&O Brand name.
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37. PRIMARY FORMS OF IDENTIFICATION

HOW CAN YOU AVOID
COMMITTING AN OFFENCE?
Do not
conduct
foreign
exchange
transactions
from people
who
approach you
privately and
not in the
workplace.
Be alert to
customers
exchanging
large
amounts of
cash, ensure
that you
always follow
the MLR
guidelines.
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Be alert of
customers
exchanging
money, more
than once, on
the same
journey. This
would be a
‘linked’
transaction of a
customer trying
to avoid
providing ID
(Smurfing).
Only accept the
approved ID. If
the customer
cannot provide
this or refuses
to provide it, the
transaction
should be
deemed as
suspicious.
Always follow
your
reporting
guidelines for
large and
suspicious
transactions.
Refer to the
AML manual
for further
guidelines
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38. SECONDARY FORMS OF IDENTIFICATION

Congratulations on completing this
training pack!
Please now click Test to take you to the AML Questionnaire or use the QR code
below on your own device.
On Completion of the questionnaire and receiving a Pass Mark you will be issued
an AML Certificate.
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