KYC & AML Policy
BA Partnership is committed to operating responsibly and ethically, ensuring that modern slavery and human trafficking have no place in any part of our business or supply chain. We take this responsibility seriously and continue to review our practices to promote transparency, fairness, and respect for human rights across all our operations.
Last Updated: 13/06/2025
1. Introduction
THE BA PARTNERSHIP (LONDON) LIMITED (“the Company”) is committed to conducting its business in accordance with all applicable laws and regulations concerning anti-money laundering (AML) and counter-terrorist financing (CTF). As part of this commitment, the Company adheres to strict Know Your Client (KYC) procedures to identify, verify, and screen all clients and suppliers before entering into any form of contractual relationship.
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This policy outlines the AML and KYC framework that governs all entities and individuals who wish to trade or transact with the Company, particularly those using our flexible and managed office solutions.
2. Platform Used: SmartSearch
The Company uses SmartSearch, a secure and regulated online platform, to carry out electronic identity verification (eIDV) and AML screening checks on all relevant parties. These checks include real-time sanction list screening, Politically Exposed Person (PEP) identification, adverse media checks, and documentation verification.
All identity data collected via SmartSearch is stored and managed securely in compliance with the UK’s Data Protection Act and GDPR standards.
3. Scope of KYC/AML Checks
The following parties will be subject to KYC/AML checks:
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Companies (corporate clients or suppliers)
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Company Directors (owning 25% or more of the entity)
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Ultimate Beneficial Owners (UBOs) (holding 25% or more direct or indirect ownership)
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Persons of Significant Interest (POSIs) as defined by UK Companies House
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No services will be rendered or agreements entered into until the KYC/AML checks are successfully completed.
4. Identification and Verification Requirements
For Companies
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Full company name
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Company registration number
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Registered office address
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Trading address (if different)
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Nature of business
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Proof of incorporation (e.g., Certificate of Incorporation)
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Recent utility bill or bank statement (dated within the last 3 months)
For Directors, UBOs, and POSIs
Each individual falling under these categories must provide the following:
1. Proof of Identity (one of the following):
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Valid passport
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UK or EEA photo driving licence
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National ID card
Proof of Address (one of the following, dated within the last 3 months):
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Utility bill
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Bank or building society statement
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Council tax bill
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HMRC correspondence
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Verification will be carried out electronically using SmartSearch to authenticate documents and cross-check against official databases.
5. Politically Exposed Persons (PEPs) & Sanctions Screening
SmartSearch will be used to identify whether any Director, UBO, or POSI is classified as a Politically Exposed Person (PEP), is subject to international sanctions, or appears on any adverse media databases. If such flags arise, the Company will conduct an internal risk assessment to determine whether to proceed.
6. Multi-Company Registration & Fees
If an individual or organisation wishes to register more than one company at any of THE BA PARTNERSHIP (LONDON) LIMITED’s business addresses, an additional due diligence process will be conducted for each company.
A processing and administrative charge of £TBC per additional company will apply.
7. Denial of Services
If any company, director, UBO, or POSI:
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Fails the KYC/AML checks,
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Provides false or misleading information,
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Refuses to provide required documentation, or
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Is linked to sanctioned or high-risk activities,
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then the Company reserves the right to deny or terminate the provision of services without notice or liability. This includes access to physical office space, virtual office services, mail handling, or any other managed office solutions.
8. Record Keeping
All KYC/AML records will be retained securely for a minimum of five (5) years from the end of the business relationship, in accordance with UK regulatory obligations. This includes copies of identification documents, correspondence, and verification results.
9. Ongoing Monitoring
The Company may perform periodic reviews or re-verification of identity information at its discretion. Triggering events for ongoing monitoring may include:
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Changes in ownership
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Red flags during mail or office usage
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Expiry of identification documents
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Regulatory updates
10. Staff Training and Compliance
All relevant staff will be trained in AML and KYC procedures, including how to identify suspicious behaviour and report it internally. Training will be updated regularly to reflect changes in legislation or risk.
11. Reporting Suspicious Activity
In accordance with UK law, any suspicious activity will be reported to the National Crime Agency (NCA) by the Company’s designated Money Laundering Reporting Officer (MLRO), without informing the subject of the report (to comply with “tipping-off” rules).
12. Review of Policy
This policy will be reviewed annually or as needed to ensure it remains compliant with applicable AML/KYC legislation, regulations, and best practices.
Approved by:
Tony Steel
Operations Director
THE BA PARTNERSHIP (LONDON) LIMITED
Date: 13th June 2025