Aml Policy

1. Purpose

This Anti-Money Laundering (AML) Policy sets out the measures PARTXSHOP UK LIMITED LTD (trading as SEO In Context) takes to prevent its services from being used for money laundering or terrorist financing, in compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) and the Proceeds of Crime Act 2002 (POCA).

2. Scope

This policy applies to all staff, contractors, and clients of PARTXSHOP UK LIMITED LTD (trading as SEO In Context). While digital marketing agencies are not designated "relevant persons" under MLR 2017 Schedule 1, we voluntarily implement proportionate AML measures as part of our commitment to ethical business practices and our obligation to report suspicious activity under POCA Part 7.

3. Client Due Diligence (CDD)

Standard CDD: For all clients, we verify: company name, registration number (Companies House or equivalent), registered address, and primary contact identity. Enhanced CDD: For high-value engagements (>€5,000), new markets, or complex corporate structures: proof of identity for beneficial owners (25%+ shareholding), source of funds declaration, and PEP (Politically Exposed Person) screening.

4. Risk Assessment

We assess AML risk based on: client geography (FATF high-risk jurisdictions), industry sector, transaction size, corporate structure complexity, and payment method. High-risk indicators trigger enhanced due diligence before engagement.

5. Suspicious Activity Reporting

Any staff member who suspects money laundering must report internally to our Nominated Officer. The Nominated Officer will assess and, where appropriate, file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) via the SAR Online portal. Tipping off is a criminal offence under POCA s.333A.

6. Record Keeping

AML records retained for 5 years after the end of the business relationship (MLR 2017, Reg. 40). Records include: CDD documentation, risk assessments, transaction records, and internal SAR reports.

7. Training

All staff receive AML awareness training on joining and annually thereafter, covering: recognising suspicious activity, reporting procedures, and legal obligations under POCA and MLR 2017.

8. Nominated Officer

Our Nominated Officer (MLRO) can be contacted at: compliance@seoincontext.com. Last updated: March 2026.