Statement against Financial Crime

At Clarke Willmott LLP (‘Clarke Willmott’), we are committed the prevention of all financial crime, including the prevention of the criminal facilitation of tax evasion.

We have implemented strict controls to meet regulatory obligations and financial crime legislation, including the Criminal Finances Act 2017, The Proceeds of Crime Act 2002, The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, The Bribery Act 2010, The Terrorism Act 2000, and Economic Crime (Transparency and Enforcement) Act 2022.

We recognise the importance of informing our clients, the public, our employees and all individuals/organisations associated with the firm of these values and our commitment to the prevention of crime.

What do we do to mitigate the risk?

Our procedures include, but are not limited to:

• Putting in place robust policies and procedures which cover the firm, staff and associated persons. These are available to all management and staff at Clarke Willmott and contain details of how to report any concerns. To ensure compliance all staff must undertake mandatory training. Disciplinary action will be taken in circumstances where tax evasion, or the facilitation of tax evasion, by any member of staff has been proven.
• Updating our policies on procurement, outsourcing, instructing experts and VAT for clients outside the UK, to ensure the necessary due diligence is carried out.
• We undertake due diligence on all clients, beneficial owners and connected persons at the start of the business relationship to verify identity and our relationship with them to obtain necessary background information including source of funds and wealth used in any transaction.
• On a regular ongoing basis, we undertake a risk assessment for each client and matter. Where any high-risk factors are identified, we can undertake enhanced due diligence and investigate further. There may be circumstances where we are not able to proceed with the instruction and cease to act for a client.
• If we know or suspect a transaction involves financial crime, we may be required to make a disclosure to the relevant authorities and will not be able to tell the client that a disclosure has been made.

This activity is to support of our committed to protecting our clients and colleagues maintaining the highest standards of care and service to our clients.

This statement will be reviewed annually. The next review is due March 2025.

Peter Swinburn
Chief Executive