KYC & AML POLICY
Information about the Company: NETPEAK LTD
Company type: Private Limited Company
Company number: 08991979
Registered office address 41 Devonshire Street, Ground Floor, London, United Kingdom, W1G 7AJ
Effective Date: October 16, 2025
Version: 1.0
Approved by the Director of NETPEAK LTD, Mr. Trevor Malcolm Gedeon
1. PURPOSE
This policy establishes the framework for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance for a UK-registered digital marketing agency. The agency provides online marketing, advertising management, and analytics services to clients globally. It does not engage in financial intermediation or crypto-asset services, but may accept cryptocurrency as a form of payment for its own services. The purpose is to ensure transparency, integrity, and full compliance with UK AML obligations.
2. LEGAL FRAMEWORK
The agency complies with the following legislation and regulatory guidance:
Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended);
Proceeds of Crime Act 2002;
Sanctions and Anti-Money Laundering Act 2018;
HMRC guidance for businesses in the UK;
FATF Recommendations (international standards).
3. SCOPE
This policy applies to all business relationships, suppliers, contractors, and clients. It is relevant to all employees, representatives, and officers involved in client onboarding, invoicing, or financial transactions.
4. KYC / DUE DILIGENCE PROCEDURES
The agency performs Customer Due Diligence (CDD) on each new client before initiating a business relationship.
This includes:
Verifying the client's legal name, registration, and business address;
Identifying Ultimate Beneficial Owners (UBOs);
Assessing the client's jurisdictional and business risk;
Retaining verification records for at least 5 years.
5. ENHANCED DUE DILIGENCE (EDD)
EDD is applied when clients are from high-risk jurisdictions, use crypto-assets for large payments, or are politically exposed persons (PEPs). The agency may request additional information, such as proof of source of funds or wealth, and seek senior management approval prior to onboarding.
6. ONGOING MONITORING
Client relationships are reviewed annually or upon changes in ownership or activity. The agency monitors payments for unusual patterns and escalates any suspicious activities to the director as MLRO (Money Laundering Reporting Officer).
7. RECORD KEEPING
All KYC documents, contracts, invoices, and communication records are retained securely for a minimum of five years from the end of the business relationship. Records are accessible for regulatory inspection upon request.
8. TRAINING
All employees, representatives, and officers involved in client relations receive annual AML awareness training to recognise suspicious activity and report it to the MLRO.
9. CRYPTO-ASSET PAYMENTS
The agency may accept cryptocurrency (e.g., BTC, ETH, USDT) as payment for its own marketing services. It does not provide crypto-asset custody, exchange, or trading services, and is therefore not a Crypto-Asset Service Provider (CASP). The agency verifies the source of funds and retains relevant blockchain transaction records. Suspicious crypto transactions are reported to the MLRO and, if necessary, to the National Crime Agency (NCA).
10. SANCTIONS AND COMPLIANCE CHECKS
The agency screens all new clients and counterparties against UK, EU, and UN sanctions lists before entering a business relationship. Any match results in immediate suspension pending review.
11. REVIEW AND UPDATES
This policy is reviewed annually or sooner if there are changes in law, operations, or business risk exposure. Updates must be approved by the director and/or senior management.
