Anti-Money Laundering Compliance For Currency Exchange Company


This is a complete guide for currency exchange companies who wish to comply with strict UK compliance.

Currency Exchange and Money Transfer businesses are vulnerable to Money Laundering. National Crime Agency, HMRC and FCA are taking efforts to stop money Laundering and prosecute individuals or businesses who support, promote and facilitate money laundering. As a business it is your legal binding to Know Your Customer before transacting with them.

Who is Nominated Officer?

Each currency exchange company should appoint a nominated officer; also known as Money Laundering Officer MLRO. It’s his/her responsibility to outline company’s policies and procedures to fight money laundering. If you are a one person company then you will be the nominated officer unless you appoint an external compliance officer. You will need a currency exchange software which will help you comply with your responsibilities.

When should I ask for a Photo ID from customer?

It’s better to know your customer; even if they are transacting few hundreds with you, it’s always recommended to ask questions like, “Do you work nearby?”, “Going on a family holiday?”. Ask if the customer has a Photo id on them and if they say yes then enter the ID details with the currency transaction.

Your compliance officer or Wholesale dealer may have given a threshold amount to make it mandatory to collect id document from customer. Say for example, if customer is transacting more than £4,000.00 you need to ask the customer for a Photo Identification document. If the customer fails to present an ID or refuses too, then it is recommended to decline the transaction.

If you find anything suspicious then try to gather maximum information and report it to your MLRO who is responsible to generate SAR (Suspicious Activity Report) and submit it to NCA.

No cashier should split the amount in to small amounts and transact. You will be held guilty for Tipping off which is a criminal offence. As the transaction amount increases, you should ask the customer to present Proof of Address and Source of Funds. The threshold amounts should be defined in your company’s AML Procedures document. Money exchange system with threshold alerts will remind cashiers to ask for an id proof from customers wherever mandatory. This will help your company to comply with legal compliance procedures.

How can I check if the customer is not a defaulter?

You are bonded by law to check all your customers against the UK and EU Sanctions List. You may further scan the customer name or document id against OFAC SDN list or UN sanctions list. Sanctions list are available on respective Government authorities website and free to download.
The currency exchange software that you use must have this functionality. Best way to confirm this is asking for free trail of the money exchange software and checking all your compliance needs.

Who reports suspicious activity to NCA?

MLRO. It is legal binding on MLRO to report any suspicious activity to National Crime Agency within 24 hours. Suspicious Activity Report SAR can be submitted online on NCA’s website or by post. Online SAR is recommended as it is quickest medium to notify NCA and gives NCA officers time to counter money laundering.

Why our Currency Exchange Bureau System CEBS is best at compliance?

CEBS does transactions worth £2.9 million every month. The system performance ranks high with security and compliance being top most priority.

CEBS users are self-trained to adhere to the strong policies set by their MLRO.

CEBS is one of the favourite currency exchange software in the UK.
Below are few of the reasons:

  • HMRC and FCA guidelines compliant
  • Customer names searched against updated Sanctions List of the UK, EU, UN and US
  • Various profit calculation formulas
  • All currencies in the world supported
  • Strong reporting tool
  • Cloud based and secured
  • Easy to use. Minimal training required. Video library available. 24 X 7 support.
  • Can be customised to serve our global customers.

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Are you a start up? We know starting a currency exchange business with limited funds is a challenge. Affordable and efficient systems is what you would be looking for. We offer competitive pricing for our system. Our pricing is based on number of licences, single or multi-branch and wildcard option.

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Note: This guide is published for better understanding of compliance to fight anti-money laundering. Calyx Solutions UK Ltd will not be held liable for any loss incurred either financial or licensing by following this guide.