These are the Anti-Money Laundering (ALM) Policy and Procedures adopted by Robson Scott Associates in compliance with The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR). The business will actively prevent and take measures to guard against being used as a medium for money laundering activities and terrorism financing activities and any other activity that facilitates money laundering or the funding of terrorist or criminal activities.

To these ends:

• The identities of all new and existing clients will be verified to a reasonable level of certainty.
• A risk-based approach will be taken to the monitoring of client tax and accounting affairs.
• Any suspicious activity will be reported, and all AML activities recorded
• Christopher David Horner will act as the Money Laundering Reporting Officer (MLRO) to coordinate the AML policies and procedures of the business.
• All staff that meet or contact clients and potential clients of this firm are required to acknowledge that the policy and procedures have been read and understood before meeting or contacting clients.