Anti-Money Laundering and Client Acceptance Policy 

1.       PURPOSE OF THIS NOTICE

The purpose of this notice is to explain how and why Circular3 carries out client acceptance procedures and anti-money laundering (AML) checks before providing services.

Please read the following carefully to understand our practices regarding complying with applicable laws and professional standards; and accepting and continuing to work with clients.

2.      OUR LEGAL AND REGULATORY RESPONSIBILITIES

As a regulated professional service provider, Circular3 is required to comply with anti-money laundering (AML) and counter-financial crime legislation, including the Money Laundering Regulations 2017 (as amended) and the Proceeds of Crime Act 2002.

This includes:

  • Verifying the identity of clients before providing certain services

  • Understanding the nature and purpose of the engagement

  • Identifying and verifying beneficial owners and Persons with Significant Control (PSCs), where applicable

  • Maintaining appropriate records

  • Monitoring for unusual or suspicious activity

Where required by law, Circular3 must report suspected money laundering, fraud, tax evasion, or other criminal activity to the relevant authorities. In such circumstances, we may be legally prohibited from informing the client that a report has been made.

3.      CLIENT ACCEPTANCE AND DUE DILIGENCE

Client Due Diligence (CDD) is carried out before services are provided and applies to:

  • All new clients

  • Any Person with Significant Control (PSC) or beneficial owner

  • Existing clients where circumstances change

CDD is a chargeable professional service and is required as part of our regulatory obligations. Fees for due diligence and onboarding are non-refundable.

Clients will be asked to provide:

  • Identification documents

  • Proof of address

  • Personal or business information

  • Details of ownership, control, or structure

  • Information about the purpose of the engagement

As part of our verification procedures, Circular3 may:

  • Verify information provided against independent and reliable sources

  • Carry out electronic identity verification checks

  • Conduct credit reference or financial background checks where appropriate

These checks are used solely for client verification, risk assessment, and fraud prevention purposes.

Circular3 applies a risk-based approach. The level of due diligence required will depend on:

  • The complexity of the structure or arrangements

  • The jurisdictions involved

  • The nature of the services requested

  • The perceived level of risk

Where enhanced due diligence is required, additional information and checks may be necessary.

Circular3 reserves the right to decline or discontinue services where satisfactory due diligence cannot be completed.

4.      IDENTITY VERIFICATION FOR REMOTE SERVICES

Where services are provided remotely, Circular3 applies additional measures to verify the identity of clients in accordance with the Money Laundering Regulations 2017 and relevant professional guidance.

In addition to our client due diligence procedures:

  • A live video meeting is required so that the advisor can confirm that the individual presenting the identification matches the person receiving the service

Non face-to-face relationships are treated as presenting a higher risk. Circular3 applies a risk-based approach, and additional information or enhanced due diligence may be required where the level of risk is considered higher.

Where satisfactory identity verification cannot be completed, Circular3 will be unable to provide services.

5.       INTEGRITY AND STATUTORY COMPLIANCE

Circular3 works with clients to ensure compliance with applicable statutory and regulatory requirements.

Where we identify that an error, omission, or non-compliance has occurred, we will:

  • Inform the client promptly

  • Explain the corrective action required

  • Support the client in making the necessary disclosure or correction

  • Assist in regularising the position, including the payment of any tax, penalties, interest, or other charges that may be due

This approach reflects our professional obligations to act with integrity and in accordance with the law.

6.       CLIENT COOPERATION AND DISENGAGEMENT

Clients are expected to act honestly, provide accurate information, and cooperate fully with regulatory and compliance requirements.

Circular3 reserves the right to withdraw from an engagement where a client:

  • Fails to provide required information or due diligence documentation

  • Is unwilling to cooperate with reasonable compliance requests

  • Refuses to correct a known error or irregularity

  • Requests that we act in a way that is unlawful, misleading, or inconsistent with professional or regulatory obligations

Where required, further action may be taken in accordance with legal and regulatory requirements.

7.       OUR COMMITMENT

Circular3 is committed to maintaining the highest standards of integrity, objectivity, and professional conduct.

We aim to provide practical, commercially focused advice that supports clients in managing their affairs efficiently and in accordance with the law. However, we do not engage in, promote, or support aggressive tax avoidance or arrangements that seek to exploit the spirit of the law or rely on artificial or contrived structures.

Our advice is provided independently and objectively. We will not allow commercial considerations, client pressure, or undue influence to compromise our professional judgement or the integrity of the advice we provide.

Where a client requests or expects an approach that is inconsistent with legal requirements, professional standards, or our ethical obligations, we will decline to act or will withdraw from the engagement.

These principles reflect our commitment to acting in the best interests of our clients while maintaining public trust and complying with applicable laws, regulations, and professional standards.