Anti-Money Laundering Policy
Apollo Accreditation
1. Scope and honesty about it
Apollo Accreditation provides consultancy services. We are not a bank, a payment institution or a designated non-financial business subject to the full customer due diligence regime.
We nonetheless apply the controls in this policy, because a consultancy that takes large payments from organisations it has not checked is an easy vehicle to misuse.
2. Risk in our business
The realistic risks are three: a client paying with funds from an unlawful source, a client structuring payments to obscure their origin, and an engagement used to give a shell organisation an appearance of legitimacy through apparent accreditation.
3. Client checks
Before we accept an engagement we identify the organisation, confirm it exists in the register of the jurisdiction it claims, identify who we are dealing with and their authority to bind it, and understand what the organisation actually does.
Where ownership is opaque, where the organisation cannot be found in a public register, or where the stated purpose does not match the request, we do not proceed until it is explained.
4. Payments
We accept payment only by bank transfer from an account in the client's own name. We do not accept cash, we do not accept payment from unconnected third parties, and we do not accept overpayment followed by a refund request.
5. Sanctions
We screen clients against applicable European Union, United Kingdom and United Nations sanctions lists before engagement, and we do not act for a designated person or entity.
6. Reporting
Where anyone in the organisation has a suspicion of money laundering or terrorist financing, they report it internally without discussing it with the client, and we take advice on whether an external report is required. Tipping off is prohibited.
7. Records
Identification and engagement records are kept for five years from the end of the relationship, then deleted. Retention is covered in our privacy notice.
8. Review
Reviewed annually and on any material change to our services or the law.