Anti-Money Laundering Commitment

DGL Commercial Finance Ltd is committed to preventing money laundering, terrorist financing and fraud. We take our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and the Proceeds of Crime Act 2002 seriously, and we apply them consistently to every client relationship.

Responsibility for our anti-money laundering arrangements rests with the Managing Director, Darren Leigh, who oversees the checks described below and any escalation arising from them.

This page is a public summary. It is not our full internal policy, which is an operational document.

We carry out customer due diligence before entering into a business relationship and before a transaction proceeds. Our checks are proportionate to the risk presented by the client, the transaction and the source of the introduction, and are refreshed where circumstances change.

We verify the identity of every client using reliable, independent sources. For individuals this normally means photographic identification together with evidence of address. Where appropriate we use electronic verification services alongside, or instead of, physical documents.

Where a client is a company, partnership or trust, we confirm its existence and standing through Companies House and other public registers, and we identify and verify the ultimate beneficial owners, directors and any person exercising significant control.

We ask for evidence of the source of funds contributed to a transaction, such as deposits, equity or fees, and where the risk profile requires it we also establish the source of wealth. Lenders carry out their own checks, and our work is intended to ensure a case is properly evidenced from the outset.

Enhanced due diligence is applied where a higher risk is identified. This includes politically exposed persons and their close associates, clients or funds connected with high-risk jurisdictions, unusually complex or opaque ownership structures, transactions with no apparent economic rationale, and cases where we have been unable to meet the client in person.

We monitor client relationships and transactions throughout their life, so that activity remains consistent with what we know about the client and the purpose of the funding. Where something does not fit, we ask.

Where we know or suspect, or have reasonable grounds to suspect, that funds are the proceeds of crime or are connected with terrorist financing, we are required to report the matter to the National Crime Agency. We are not permitted to tell a client that such a report has been made. Where we cannot complete our checks, we will decline or discontinue the relationship.

Verification records and supporting documents are retained securely for five years from the end of the business relationship or the completion of the transaction, as the regulations require, and are then securely destroyed. Information collected for these purposes is handled in accordance with our Privacy Policy.

Further information regarding our compliance procedures is available upon request where appropriate.