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Anti-Money Laundering Policy

Review Date: Annually

1. Policy Statement

RenewCap UK Ltd ("RenewCap") is committed to conducting business with the highest standards of integrity, transparency, and regulatory compliance. We maintain a zero-tolerance approach to money laundering, terrorist financing, fraud, corruption, sanctions breaches, and other forms of financial crime.

As a renewable energy finance and project facilitation business operating across multiple jurisdictions, including the United Kingdom and Africa, we recognise our responsibility to ensure that our services, systems, funding arrangements, and business relationships cannot be used to facilitate criminal activity or conceal the proceeds of crime.

RenewCap is committed to implementing effective controls to identify, prevent, detect and report suspicious activities and to ensure compliance with all applicable anti-money laundering ("AML") and counter-terrorist financing ("CTF") legislation and regulatory requirements.

This policy applies to all directors, employees, contractors, consultants, partners, agents, intermediaries and third-party representatives acting on behalf of RenewCap.

 

2. Regulatory Framework

RenewCap's AML framework is designed to support compliance with:

  • Proceeds of Crime Act 2002 (POCA)
  • Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
  • Terrorism Act 2000
  • Criminal Finances Act 2017
  • Sanctions and Anti-Money Laundering Act 2018
  • UK Financial Sanctions Regulations
  • Office of Financial Sanctions Implementation (OFSI) guidance
  • National Crime Agency (NCA) reporting requirements
  • Relevant FCA guidance and financial crime best practices

RenewCap will monitor legislative developments and update its controls where necessary.

 

3. Our AML Principles

RenewCap operates in accordance with the following principles:

Risk-Based Approach

We assess and manage money laundering and terrorist financing risks based on customer profile, transaction type, geographic location, payment methods, delivery partners and funding arrangements.

Know Your Customer (KYC)

We seek to establish the identity of customers and counterparties before entering into business relationships or processing transactions where required by law or risk assessment.

Transparency and Traceability

All transactions must be fully documented, auditable and linked to legitimate business activities.

No Cash Transactions

RenewCap does not accept cash payments, cash deposits, cash equivalents, anonymous payments or informal value transfer mechanisms under any circumstances.

Escalation and Reporting

Employees are required to report any suspicious activities immediately through established reporting channels.

 

4. Governance and Accountability

The Board of Directors has ultimate responsibility for overseeing financial crime compliance within RenewCap.

Money Laundering Reporting Officer (MLRO)

The Board shall appoint a suitably experienced Money Laundering Reporting Officer (MLRO) who is responsible for:

  • Oversight of AML compliance
  • Receiving and assessing internal suspicious activity reports
  • Conducting investigations where appropriate
  • Maintaining AML procedures and records
  • Liaising with regulators and law enforcement agencies
  • Submitting Suspicious Activity Reports (SARs) to the National Crime Agency
  • Delivering AML training and awareness programmes
  • Monitoring sanctions compliance

The MLRO shall have unrestricted access to information necessary to fulfil these responsibilities.

5. Customer Due Diligence (CDD)

RenewCap adopts a risk-based customer due diligence framework.

Prior to establishing business relationships or accepting certain payments, we may verify:

Individual Customers

  • Full name
  • Date of birth
  • Residential address
  • Government-issued identification
  • Source of funds where appropriate

Corporate Customers

  • Company registration details
  • Registered address
  • Directors and officers
  • Ultimate beneficial owners (UBOs)
  • Source of funds and business activities

Verification may be carried out using:

  • Electronic identity verification services
  • Government-issued documentation
  • Corporate registry searches
  • Independent third-party databases
  • Bank verification procedures

Where information cannot be satisfactorily verified, RenewCap reserves the right to decline or terminate the relationship.

6. Enhanced Due Diligence

Enhanced Due Diligence (EDD) shall be applied to higher-risk situations, including but not limited to:

  • Politically Exposed Persons (PEPs)
  • Relatives and close associates of PEPs
  • High-risk jurisdictions
  • Complex ownership structures
  • Unusual transaction arrangements
  • Transactions involving multiple intermediaries
  • High-value transactions
  • Cross-border payment structures presenting elevated risk
  • Situations where source of funds cannot be readily established

EDD may include obtaining additional information, senior management approval, enhanced monitoring and independent verification of source of wealth and source of funds.

7. Funding and Payment Controls

RenewCap's business model incorporates specific controls designed to mitigate financial crime risk.

Regulated Lending

Where customer financing is provided through a lending partner, all lending decisions, affordability assessments and regulated financial checks are undertaken by the FCA-authorised lender in accordance with its regulatory obligations.

Controlled Project Funding

Where project funding arrangements are used:

  • Funds are only applied to approved renewable energy projects.
  • Project payments must correspond to verified project milestones.
  • Expenditure must be supported by appropriate documentation.
  • Payments are subject to approval controls and reconciliation procedures.
  • Full audit trails are maintained.

Restricted Payment Pathways

RenewCap does not permit:

  • Payments to unrelated or unauthorized third parties.
  • Anonymous transactions.
  • Redirected payments without appropriate verification.
  • Requests for refunds to alternative accounts.
  • Payments structured to avoid identification requirements.

8. Sanctions Compliance

RenewCap maintains procedures to identify and prevent dealings with sanctioned persons, entities or jurisdictions.

Appropriate screening may be undertaken against:

  • UK Sanctions List
  • OFSI sanctions records
  • International sanctions databases where relevant

RenewCap will not knowingly:

  • Provide services to sanctioned individuals or entities
  • Facilitate transactions involving sanctioned parties
  • Engage in prohibited transactions with sanctioned jurisdictions

Any sanctions concerns must be escalated immediately to the MLRO.

9. Transaction Monitoring and Red Flags

RenewCap monitors customer activities and transactions for indicators of potential money laundering, terrorist financing or fraud.

Examples of red flags include:

  • Reluctance to provide identification information
  • Inconsistent information regarding a transaction
  • Payments from multiple unrelated accounts
  • Requests to overpay and receive refunds
  • Attempts to route funds outside approved processes
  • Transactions lacking an apparent commercial purpose
  • Requests involving unnecessary third parties
  • Unexplained urgency or pressure to bypass controls
  • Complex structures that obscure ownership or beneficiaries

The presence of a red flag does not automatically indicate criminal activity but requires further review and escalation.

10. Suspicious Activity Reporting

All employees have a duty to report knowledge or suspicion of money laundering, terrorist financing or criminal property.

Where concerns are identified:

  1. The matter must be reported immediately to the MLRO.
  2. The employee must not undertake further action without guidance.
  3. Appropriate records must be maintained.
  4. The MLRO will determine whether a Suspicious Activity Report (SAR) should be submitted to the National Crime Agency.

Under no circumstances may employees disclose or imply to any person that a SAR has been made or that an investigation is underway.

Such conduct may constitute the criminal offence of "tipping off".

11. Record Keeping

RenewCap maintains accurate records sufficient to demonstrate compliance with AML obligations.

Records may include:

  • Customer due diligence documentation
  • Identity verification records
  • Beneficial ownership information
  • Transaction records
  • Risk assessments
  • Internal investigations
  • Suspicious activity reports
  • AML training records

Records shall be retained for a minimum period of five years or longer where required by law, regulation or contractual obligation.

12. Training and Awareness

All relevant personnel shall receive AML and financial crime awareness training:

  • On commencement of employment or engagement
  • At least annually thereafter
  • Following significant legal or regulatory changes
  • When business activities create new financial crime risks

Training shall be proportionate to each individual's role and responsibilities.

13. Monitoring and Review

RenewCap will regularly review the effectiveness of its AML framework through:

  • Periodic risk assessments
  • Internal compliance reviews
  • Management oversight
  • External audits where appropriate
  • Regulatory developments monitoring

This policy shall be reviewed at least annually or when significant changes occur to the business model, regulatory environment or financial crime risk profile.

14. Non-Compliance

Failure to comply with this policy may result in:

  • Disciplinary action
  • Termination of employment or engagement
  • Reporting to regulators or law enforcement
  • Civil or criminal liability

RenewCap reserves the right to decline, suspend or terminate any transaction or business relationship where financial crime concerns cannot be satisfactorily resolved.

 

RenewCap UK Ltd is committed to maintaining robust anti-money laundering controls and ensuring that renewable energy investment and infrastructure financing is conducted responsibly, transparently and in full compliance with applicable laws and regulations.

Approved by the Board of Directors
RenewCap UK Ltd