Anti-Money Laundering Policy

This policy sets out the framework by which Helios Trade Ltd complies with the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended), the Proceeds of Crime Act 2002, the Terrorism Act 2000 and the Bribery Act 2010.

It applies to all directors, employees, contractors and business partners of Helios Trade Ltd.

We adopt a risk-based approach to identifying, assessing and mitigating money laundering and terrorist financing risks across our supplier, distribution and buyer relationships. Risk assessments consider jurisdiction, product category, transaction pattern, ownership structure and payment channels.

Before onboarding any brand, supplier or wholesale buyer we perform Customer Due Diligence (CDD), including:

• Verification of legal identity, company registration and trading address.
• Identification of Ultimate Beneficial Owners (UBOs) holding 25% or more.
• Screening against UK, EU, UN and OFAC sanctions and PEP lists.
• Confirmation of VAT registration and, where relevant, industry authorisations.
• Assessment of the source of funds and nature of business.

Enhanced Due Diligence (EDD) is applied to higher-risk relationships, including PEPs, high-risk jurisdictions and complex ownership structures.

Business relationships and transactions are monitored on an ongoing basis to detect activity inconsistent with our knowledge of the customer. Records are periodically refreshed and re-verified.

• Payments are accepted only through regulated banking channels.
• Cash payments are not accepted.
• Third-party payments (from a party other than the contracting customer) are not accepted without documented justification and approval.
• Payment instructions must match verified account details on file.

We do not trade with sanctioned individuals, entities or jurisdictions. All counterparties are screened before onboarding and periodically thereafter. Any positive or potential match halts the transaction pending investigation.

Staff are trained to identify red flags and must promptly report any suspicion of money laundering or terrorist financing to the nominated Money Laundering Reporting Officer (MLRO). Where suspicion is confirmed, a Suspicious Activity Report (SAR) is submitted to the UK National Crime Agency (NCA).

"Tipping off" the subject of a report is a criminal offence and is strictly prohibited.

KYC, transaction and correspondence records are retained for a minimum of 5 years after the end of a business relationship, in line with UK AML regulations.

All staff receive AML and financial crime training on induction and at regular intervals. The MLRO reports directly to the board and reviews this policy at least annually.

To report a concern or request further information, contact our MLRO at info@heliostradeltd.com.