Anti-Money Laundering Policy

1. Overview

black sofa is committed to preventing money laundering, fraud and financial crime.

We take a practical, risk-based approach to ensure our services are not used for unlawful purposes, while keeping things straightforward for our clients.

2. What This Means

Money laundering is the process of disguising the origins of illegally obtained funds to make them appear legitimate.

As a payroll and payments related service provider, we recognise the importance of identifying and managing this risk.

3. Our Approach

We apply proportionate controls designed to:

• Identify who we are working with
• Understand the nature of the relationship
• Monitor for unusual or suspicious activity

Our approach is guided by UK regulations and industry best practice.

4. Record Keeping

All CDD records are retained for at least 5 years after the end of the business relationship.

5. Training

All relevant staff receive regular AML training appropriate to their role.