Anti Money-Laundering Policy

BISSH – British Institute of Skills and Simulation in Healthcare (“we”, “us”, “our”) is committed to preventing money laundering and terrorist financing. This policy sets out our approach in line with UK law, including the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 (POCA), and the Terrorism Act 2000.

1. Scope and commitment

We operate a zero-tolerance approach to money laundering and terrorist financing. All staff, associates and relevant parties are expected to understand and comply with this policy and with UK legal obligations. We will not enter into or continue business relationships where we have grounds to suspect money laundering or terrorist financing.

2. Risk-based approach

We assess and manage the risk of money laundering and terrorist financing in our operations. Where our activities fall within the scope of MLR 2017 (e.g. if we provide relevant services that bring us under the Regulations), we will:

• Carry out customer due diligence (CDD) where required
• Conduct ongoing monitoring of business relationships
• Maintain records as required by the Regulations
• Ensure staff are trained and aware of their responsibilities

If BISSH is not required to be regulated under MLR 2017, we still adhere to the spirit of the UK anti money-laundering framework and report any suspicious activity as required by POCA.

3. Suspicious activity reporting

Any person who knows or suspects that another person is engaged in money laundering must report this to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR) as required by POCA. We have internal procedures to identify and escalate such concerns. It is a criminal offence to “tip off” a person that a report has been or may be made; staff must not do so.

4. Record-keeping

Where we are subject to MLR 2017, we will retain records of CDD and transactions for at least five years after the end of the business relationship or transaction, in accordance with the Regulations. Such records will be kept secure and available to relevant authorities as required by law.

5. Training

Relevant staff and associates receive training on anti money-laundering and counter-terrorist financing obligations, including recognition of red flags and reporting procedures. Training is updated periodically to reflect changes in law and risk.

6. Governance

Overall responsibility for this policy and for compliance with UK anti money-laundering law sits with senior management. We review this policy and related procedures regularly and when the law or our activities change.

7. Contact

For questions about this Anti Money-Laundering Policy, please contact us via our Contact page. Do not use this channel to report suspected money laundering; follow internal reporting procedures or contact the NCA as required by law.