1. Introduction

Glossary

• Anti-Money Laundering (AML)

• Client Due Diligence (CDD)

• Counter-Terrorist Financing (CTF)

• Enhanced Due Diligence (EDD)

• Regular Due Diligence (RDD)

• Simplified Due Diligence (SDD)

• National Crime Agency (NCA)

• Legal Sector Affinity Group AML Guidance (March 2018, updated in 2020)

• The Proceeds of Crime Act 2002 (POCA)

• The Terrorism Act 2000 (TA)

• MLR: The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)

2. Definitions

Money laundering is the process by which the origin of the proceeds of crime is disguised to appear legitimate.
Terrorist financing involves providing or collecting funds for the purpose of carrying out acts of terrorism.

3. Role of the Notary in AML/CTF

As a Notary Public and legal professional, I, Georgeta Andrei, have a duty to detect and report money laundering or terrorist financing under the AML/CTF regimes. Non-compliance may result in criminal penalties, fines, and reputational damage.

4. Stages of Money Laundering

1. Placement

2. Layering

3. Integration

My practice is most vulnerable at the layering stage, though risk exists at all stages.

5. Red Flags

I remain vigilant for suspicious behavior such as:

• Secretive or evasive clients

• False identification

• Unusual or high-risk jurisdictions

• Pressured video conferencing

• Overpayment of fees

• Instructions inconsistent with previous conduct

6. Money Laundering Offences (POCA)

Sections 327–329 outline serious offences like:

• Concealing, transferring, or acquiring criminal property

• Becoming involved in arrangements that facilitate the use of criminal property

7. Terrorist Financing Offences (TA)

Includes possession, use, or laundering of terrorist funds, fundraising for terrorism, and tipping off.

8. Compliance with MLR

I implement systems and controls tailored to notarial work subject to the MLR, ensuring appropriate client identification and risk-based due diligence.

9. Suspicious Activity Reports (SARs)

Where knowledge or suspicion arises, I will file a SAR with the National Crime Agency in accordance with POCA/TA requirements.

10. Client Due Diligence (CDD)

CDD is conducted when:

• Establishing a business relationship

• Carrying out certain regulated transactions

• There is suspicion or doubt about client identity

CDD includes:

• Verifying identity and beneficial ownership

• Understanding the nature and purpose of the transaction

• Ongoing monitoring

11–17. Detailed CDD Procedures

These sections (retained from the original policy) remain unchanged in their applicability to Notary Northampton Ltd. They cover:

• Record keeping

• SDD/EDD/RDD thresholds

• Beneficial owner checks

• Source of funds

• Inability to complete CDD

• Reliance on third parties

• Ongoing monitoring

18. Payments from Third Parties

I investigate any payment received from third parties to ensure legitimacy and transparency.

19. Cash Payments

I accept cash for fees only, in accordance with HM Treasury guidance. I never accept cash for transaction funds.

20. Training

I undertake regular AML/CTF training and stay updated with legislative changes.

21. Policy Review

This policy is reviewed annually, and also upon:

• Changes to law or regulation

• Material changes to my notarial practice

Georgeta Andrei, Notary Public
Notary Northampton Ltd
Policy last reviewed: 4th July 2025