Version: 1.0
1. Purpose
This Anti-Money Laundering (AML) Policy sets out how The PandaBee Company Ltd T/A PandaBee Giveaways ("the Company") prevents, detects, and reports money laundering and terrorist financing.
2. Scope
This policy applies to all directors, officers, employees, contractors, and agents involved in operating competitions or handling payments, prizes, or customer data.
3. Legal Framework
The Company operates in accordance with:
- The Proceeds of Crime Act 2002
- The Terrorism Act 2000
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- The Gambling Act 2005 (as applicable)
- Guidance issued by UK regulators and enforcement authorities
4. Risk-Based Approach
The Company applies a proportionate, risk-based approach, considering:
- Customer behaviour and transaction patterns;
- Prize values;
- Payment methods;
- Frequency and volume of entries.
Enhanced checks may be applied where higher risk indicators are identified.
5. Customer Due Diligence (CDD)
The Company may require winners (and, where appropriate, entrants) to provide identity and address verification, including but not limited to:
- Government-issued photo identification; and
- Proof of address dated within the last three months.
Failure to provide satisfactory verification may result in disqualification and forfeiture of the prize.
6. Transaction Monitoring
The Company monitors transactions to identify unusual or suspicious activity, including:
- Multiple or excessive entries;
- Attempts to circumvent entry limits;
- Repeated high-value transactions without clear rationale.
7. Reporting Suspicious Activity
Any suspected money laundering or terrorist financing activity will be reported in accordance with legal requirements.
A Suspicious Activity Report (SAR) may be submitted to the National Crime Agency (NCA) where appropriate.
8. Record Keeping
The Company retains AML-related records, including identification and transaction data, for a minimum of five (5) years, or longer where legally required.
9. Training
Relevant staff receive AML awareness training appropriate to their role, including recognising suspicious behaviour and understanding reporting obligations.
10. Responsibility and Oversight
A designated Money Laundering Reporting Officer (MLRO) oversees AML compliance.
- MLRO: Amanda Lant
- Company Position: Director of Customer Experience & Compliance
-- Contact: MLRO@pandabee.uk
11. Review
This policy is reviewed regularly and updated as required to reflect legal or operational changes.
12. Relationship to Other Policies
This AML Policy operates alongside the Company’s: