NW BROWN GROUP LIMITED

Money Laundering, Fighting Financial Crime Procedures

In adapting a risk-based approach towards the money laundering requirements we feel that it is appropriate, in order to meet the requirements of other relevant legislation e.g. Criminal Justice Act and Proceeds of Crime Act, that we implement differing procedures across the various group activities. This is to achieve an appropriate and proportional response to the risks involved across the group.

The various aspects are: -

NW Brown and Company Limited	Financial Planning Group Pensions/Employee Benefits Venture Capital Angel Investments via I.Q.
NW Brown Insurance Brokers Limited	General Insurance Mortgage Broking
Freedom Insurance Services Limited	General Insurance

 
Separate Procedures have been adopted for each firm, which set out our response to the risks associated with each business activity.

The key differences are in relation to the requirements for client identification and verification where deemed appropriate. For NW Brown & Co Limited the product risks are perceived to be high and full ID and verification procedures are adopted across all business aspects of that firm. We currently use Experian to enable a “paperless” assessment making the process simple for the client. Where third floor activities are concerned bespoke procedures are in place with specific reference made to the compliance department on a case-by-case basis. In relation to NW Brown Insurance Brokers Limited and Freedom Insurance Services Limited, however, identification verification is not required except for mortgage broking activities. Here we are constrained by the rigourous requirements of the lenders.

The consistent aspects of the three procedures relate to the general awareness and staff training required across the Group. All new staff are required to attend instruction as part of the induction process. Annual refreshers for all staff are arranged and supervised by the MLRO.  The MLRO for NW Brown & Co Limited is also the point of contact for all support and guidance across the Group. The process of reporting and recording any suspicious activity is again consistent, with the SAR forms available to all staff on the Intranet.

It is proposed that the procedures be adopted at the next Compliance Committee on 5th February 2007 and placed on the Intranet. Compliance will remind all staff of the procedures applying to their part of the business on an annual basis in addition to the refreshers conducted by the MLRO.

Nigel Masters
03/01/07