Financial Crime, AML, KYC and Sanctions Policy

Last reviewed: 8 July 2026

MANCEPS LIMITED maintains proportionate financial crime, anti-money laundering, counter-terrorist financing, know-your-customer and sanctions controls for its wholesale trading, import-export, customer, supplier and business-partner onboarding activities.

This policy supports internal controls, business partner due diligence and responsible onboarding. It does not state that MANCEPS LIMITED is registered or supervised as an AML-regulated firm unless that status is separately confirmed in writing.

Purpose

The purpose of this policy is to reduce the risk that MANCEPS LIMITED is used for money laundering, terrorist financing, sanctions evasion, fraud, or other financial crime. It explains the control principles used when reviewing customers, suppliers, logistics providers, payment counterparties and other business partners.

Scope

This policy applies to business onboarding and review activities involving MANCEPS LIMITED, including customer and supplier verification, authority checks, sanctions screening, escalation, record keeping and periodic review. Financial crime, sanctions or suspicious-activity concerns can be sent to security@manceps.co.uk.

Business Model and Product Limits

MANCEPS LIMITED is a UK-based company working with business customers and partners in wholesale trading and import-export activity. The public website is informational only and is not an ecommerce checkout, consumer retail marketplace, or third-party payment platform.

MANCEPS LIMITED does not hold client funds, provide money remittance, deposit-taking, lending, investment, cryptocurrency, or regulated payment services to consumers. Any future activity requiring a different regulatory position will be reviewed before launch.

Governance

MANCEPS LIMITED is responsible for maintaining this policy, applying onboarding controls, recording sanctions-screening outcomes, reviewing escalated cases, and keeping appropriate business records. The policy is reviewed at least annually and after material changes to the business model, products, jurisdictions, providers, or applicable legal requirements.

Risk Assessment

Onboarding and review decisions are risk-based. Relevant factors may include the legal status and location of the customer, supplier or partner; ownership and control; the role and authority of the requester; the commercial purpose of the relationship; jurisdictions involved; sanctions or politically exposed person indicators; adverse media; unusual payment patterns; complex ownership; or mismatches between company records, invoices, bank details, websites and stated business activity.

Higher-risk cases may require enhanced review, additional evidence, senior approval, legal or compliance advice, restrictions, rejection or offboarding.

Client, Supplier and Partner Verification

Before onboarding or materially changing a business relationship, MANCEPS LIMITED may verify the legal name and registration details of the counterparty, business evidence, website or online presence where available, the identity and role of the requester, written permission or authority where needed, the intended commercial purpose, and relevant bank or payment details.

MANCEPS LIMITED will not proceed with onboarding where authority, ownership, commercial purpose or payment details cannot be reasonably confirmed.

Sanctions Screening

MANCEPS LIMITED screens relevant parties where appropriate, including companies, directors, beneficial owners, controlling persons and authorised representatives. Screening may use official or provider-required sources, including the UK Sanctions List and OFSI guidance, OFAC sanctions lists, EU consolidated sanctions lists and other relevant public sources.

Where a potential match is identified, onboarding or transaction activity is paused while the match is reviewed. Confirmed sanctions matches are rejected, restricted or escalated in line with legal requirements.

Due Diligence Records

MANCEPS LIMITED keeps appropriate records of business evidence, authority and permission checks, screening date and scope, screening outcome, enhanced review decisions, rejected or restricted cases, relevant correspondence, and payment or onboarding evidence. Records are retained in line with business, accounting and legal requirements and protected by access controls.

Ongoing Monitoring

Relationships may be reviewed when a new or changed customer, supplier, partner or bank detail is introduced; ownership, control or business activity changes; a bank, provider, staff member or partner raises a concern; sanctions requirements change; or periodic review identifies new risk indicators.

Suspicious Activity and Escalation

If suspicious activity or financial-crime concern is identified, MANCEPS LIMITED may pause onboarding or activity, request additional evidence, reject or offboard the relationship, preserve records, seek legal or compliance advice, and report where legally required. Concerns should be routed to security@manceps.co.uk.

Vendors and Outsourcing

Where external screening tools, official sanctions sources, professional advisers or service providers are used, they support the due diligence process. Final onboarding and business-relationship decisions remain with MANCEPS LIMITED.

Training and Awareness

Team members involved in onboarding, trading or payment administration are expected to understand written authority requirements, sanctions-screening records, escalation indicators, high-risk jurisdictions, ownership red flags and the company’s business limits.

Review

This policy is reviewed at least annually and after material changes to MANCEPS LIMITED’s activities, counterparties, jurisdictions, service providers or legal requirements.

Contact

Financial crime, AML, KYC, sanctions or suspicious-activity concerns relating to MANCEPS LIMITED can be sent to security@manceps.co.uk.