Anti-Money Laundering (AML) Policy
Prestigious Jewellers is committed to safeguarding the integrity of our business and the luxury watch industry by preventing money laundering and financial crime. Although we are not a regulated financial institution, we operate in accordance with UK AML guidance and take proactive steps to ensure our products are not used for illicit purposes. This policy applies to all high-value watch transactions and all employees involved in customer sales.
1. Policy Commitment
Due to the high-value nature of luxury watches, they may be targeted for laundering criminal proceeds. Prestigious Jewellers maintains strict procedures to detect and deter suspicious activity. Any transaction that raises concerns may be refused, delayed, or reported to the relevant authorities.
Each member of the sales team is responsible for following AML procedures. Oversight is provided by senior management, who monitor compliance and review any cases requiring escalation.
2. Customer Due Diligence (CDD)
We apply a risk-based approach to verifying customers, tailoring checks to the transaction value, customer profile, and context of the sale.
2.1 Identification Requirements
For purchases over £1,000, customers must provide:
– One valid photographic ID (passport or driving licence)
– One proof of address dated within the last 8 weeks (utility bill or bank statement)
Documents must be received within 48 hours of request.
If documentation is not supplied or appears incomplete or suspicious, the sale will not proceed.
2.2 Transaction Limits & Accepted Payments
To reduce AML risk, Prestigious Jewellers enforces strict rules:
– Cash payments are limited to £8,500 per transaction.
– Third-party or anonymous payments are not accepted — the payer’s name must match the ID provided
2.3 Ongoing Monitoring
All transactions are monitored for unusual behaviour, including:
– Attempts to split payments to avoid ID thresholds
– Reluctance to provide identification
– Inconsistent customer information
– Rapid multiple purchases of high-value items
Any concerns must be escalated immediately to senior management for review. Additional verification may be required before a transaction can continue.
3. Suspicious Activity Reporting
Prestigious Jewellers will report any suspected money laundering activity to the appropriate authorities.
In the United Kingdom, this includes making a report to the National Crime Agency (NCA) if necessary.
Internal records are kept of any incidents, reviews, or decisions made. Management determines when a report is required and may halt or cancel any transaction linked to suspicious activity.
4. Staff Training & Compliance Checks
Well-trained staff are essential to preventing financial crime. All relevant employees receive AML training upon joining the company, along with periodic refresher sessions. Training covers:
– How to verify customer identity
– How to recognise suspicious behaviour
– How to escalate concerns
– How to follow internal reporting procedures
Management conducts periodic compliance checks, including reviewing ID collection procedures and monitoring adherence to transaction limits.
Any failures to follow this policy will be addressed through further training or disciplinary action.
5. Governance & Oversight
Senior management oversees the AML programme and ensures that the policy remains aligned with current legislation and best practices in the luxury goods sector.
Management serves as the primary point of contact for law enforcement or regulatory authorities and reviews any escalated cases of suspected financial crime.
This AML Policy is reviewed annually, or sooner if legal requirements or emerging risks require updates.