Master Anti-Money Laundering ( AML ) Compliance - Master

Anti-Money Laundering ( AML ) Compliance

“If something doesn’t feel right – report it. You don’t need to prove wrongdoing. You just need to raise your concern. ~Louis Bell ~

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Objectives

By the end of this training, participants will be able to:

• Understand why AML compliance is critical to financial integrity and crime prevention.

• Recognise Snap Finance’s legal and regulatory duties under the FCA.

• Identify common red flags and suspicious behaviors linked to money laundering.

• Distinguish between AML triggers for merchant-facing (B2B) and customer-facing (B2C) roles.

• Detect potential triggers in your own role.

• Take the correct action by reporting concerns through the internal SAR process.

Why does AML compliance matter?

Why AML Compliance Matters

Money laundering is the process of disguising the origins of illegally obtained money or assets so that they appear legitimate.

It enables serious criminal activity such as drug trafficking, terrorism, and fraud.

To protect the financial system and prevent criminal exploitation, strict laws and regulations are in place in the UK and globally.

Why Snap must comply!

Why Snap Finance Must Comply

As a regulated consumer credit firm, Snap Finance is required by the Financial Conduct Authority (FCA) to have robust AML policies and controls in place. We must ensure that:

• Criminals are not using our platform to launder money.
• We identify and report suspicious activity.
• We protect our customers, business, and the wider financial system.

Non-compliance can lead to regulatory penalties, reputational damage, and legal consequences for both the company and individuals.

Who can be the subject of a SAR

Who Could Be the Subject of a SAR?

Customers – e.g., suspicious patterns, identity issues, multiple accounts, money laundering or fraud. Merchants – e.g., excessive refunds, account manipulation, pressure to override controls, collusion. Employees/Colleagues – e.g., conflicts of interest, control overrides, unauthorized access, suspicious relationships.

The process and confidentiality duty are the same regardless of involved parties.

General Triggers for All Employees

Merchant-Facing Employees (B2B)

Customer-Facing Employees (B2C)

Business to Customer

Business to Business

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B2B AML TrigGers

Merchant-Facing Employees B2B AML Triggers

Look out for these red flags when dealing directly with Merchants : Click on the titles below to learn more :

Unusual Merchant Behaviour

Identity or Documentation Concerns

Financial Irregularities

Inconsistent Business Activity

Reluctance to Cooperate

Customer-Facing Employees ( B2C)

Look out for these red flags when dealing directly with consumers: Click on the images below to learn more :

Third-Party Interference

Suspicious Documents

Application Behaviour

Suspicious Transactions

Unusual Payment Methods

Pay-in-4 Concerns

Customer Evasion

Possible Triggers :

Here are some examples to demonstrate how these issues may present themselves in your role

Systems Change requests

Preferreantial treatement

Unexplained/unusual acceess request

Failing to record document changes

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Change Team : Possible Triggers

Possible Triggers :

Example : Failing to log or document changes to sensitive workflows Can indicate intentional avoidance of audit trails.

Example : Preferential treatment of certain stakeholders during tech rollouts. Could indicate bias or collusion to benefit particular departments or merchants.

Example : A request to Implement system changes that reduce oversight or controls without authorisation. May indicate an attempt to weaken internal defences

Here are some examples to demonstrate how these issues may present themselves in your role

A request for Unexplained access to production environments or system logs. This could indictate an attempt to cover up misconduct.

Click on a card to reveal the scenario, then discard it once reviewed

Failing to record changes to sesntive workflows

System Change Requests

Unexplained Access request

Stakeholder Bias

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Possible Triggers :

Why Snap must comply!

Here are some examples to demonstrate how these issues may present themselves in your role

Tampering with evidence or case notes

Bypassing or disabling fraud rules/alerts

Involvement in fraud rings, collusion with customers or merchants

Failure to escalate known fraud indicators or trends

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Why Snap must comply!

Possible Triggers :

Here are some examples to demonstrate how these issues may present themselves in your role

Undeclared relationships with advertising partners or agencies

Direct marketing to excluded or high-risk customer groupsr

Publishing misleading campaign content or product claims

Manipulation of performance data for campaigns

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Why Snap must comply!

Possible Triggers :

Here are some examples to demonstrate how these issues may present themselves in your role

Suppression or non-escalation of risk indicators in reports

Unexplained or unapproved journal entries or reclassifications

Manipulation of financial reporting or performance metrics

Conflict of interest

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Why Snap must comply!

Possible Triggers :

Here are some examples to demonstrate how these issues may present themselves in your role

Unapproved Contact with High-Risk Customers

Suspicious Login Activity or Shared Credentials

Improper Issuance of Refunds or Account Credits

Unauthorised amendments to Arrears or Fees

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Why Snap must comply!

Possible Triggers :

Here are some examples to demonstrate how these issues may present themselves in your role

Inappropriate handling of grievances related to fraud or financial misconduct

Accessing or sharing confidential employee records without authorisation

Failure to escalate serious conduct issues

Manipulating hiring or promotion processes

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Why Snap must comply!

Possible Triggers :

Here are some examples to demonstrate how these issues may present themselves in your role

Receiving unreported gifts, benefits, or incentives from merchants

Close or unusual ties with non-compliant or fraudulent merchants

Falsifying merchant sales figures or inflating pipeline reports

Onboarding merchants without sufficient due diligence

To help you recognise potential triggers in your day-to-day role, it's important to remain vigilant. Any suspicions or concerns should be reported immediately.

Maintaining confidentiality

Suspicious Activity Reports (SARs) are submitted to protect Snap Finance and the wider financial system from abuse. Maintaining confidentiality is not just best practice—it’s a legal requirement.

It is critical because it:

• Preserves the integrity of investigations by law enforcement or regulators.
• Prevents suspects from hiding assets, tampering with evidence, or colluding with others.
• Protects the individual submitting the SAR from retaliation or interference.
• Ensures compliance with UK financial crime legislation and regulatory obligations.

What is “Tipping Off”.

What is Tipping off and how to avoid it ?

Tipping off occurs when someone—intentionally or unintentionally—alerts a customer or third party that a Suspicious Activity Report (SAR) has been or may be submitted. This can seriously compromise investigations and is a criminal offence under UK law.

To avoid tipping off:

• Do not disclose that a SAR has been submitted or considered.
• Avoid discussing suspicions with the customer or anyone not authorised to know.
• Keep your language neutral when interacting with the customer—do not imply wrongdoing.
• Follow internal procedures strictly and report concerns only through approved channels.
• Never speculate about investigations or outcomes with colleagues or customers.

Maintaining discretion is essential to protect the integrity of the process and ensure Snap Finance remains compliant with financial crime legislation.

How to report

Reporting Your ConcernsOnce you've identified a concern, it must be recorded using the AML (Anti-Money Laundering) form. This form is available via WhatSnap!, and a direct link can also be found HERE If you are unsure, please email : suspiciousactivity@snapfinance.co.uk

Do's and Dont's - Recap

• Submit your SAR confidentially via the designated internal reporting channel or to the MLRO

• Keep your report clear, factual, and based on observations or evidence

• Cooperate discreetly with the MLRO or Compliance team if follow-up is needed

• Stay objective — you're raising concerns, not making judgments.

• Do not tell the subject of the SAR that you are suspicious or that you have reported them

• Do not guess, exaggerate, or speculate

• Do not discuss the SAR with anyone not directly involved, including peers or your line manager (unless instructed)

• Do not take matters into your own hands or attempt your own investigation

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Good Work !

Final Thought: SARs are vital in fighting financial crime. Submitting one is an ethical duty and must be kept confidential. Remember:

• You’re reporting, not investigating.
• Never tip off. Stay quiet and compliant.

• If unsure, contact Compliance confidentially.

We're here to help you do the right thing.

What does third party interference look like ?

• Another person dominates the application process on the customer's behalf.
• Signs someone else is using the account or making payments.

What would unusual behaviour look like ?

• Sudden surge in loan applications with no increase in store activity. • Many applications with identical or near-identical customer profiles. • Merchant encourages customers to misrepresent income or employment. • Pressure to approve applicants who clearly fail affordability checks.

How would I identify an unusual payment ?

• Use of prepaid cards, foreign or crypto-related accounts.
• Several accounts linked to the same bank details.

Examples of Pay-in-Four concerns

• Customer uses maximum loans repeatedly with no repayment plan.
• Pays off Pay-in-4 loans in large lump sums that don’t match their profile

Customer Evasion

Unwillingness to provide additional documentation when asked.

How would i identify Financial irregularity?

• Merchant payments come from unrelated third-party bank accounts.
• Unexplained changes in ownership, directors, or company structure

How to spot odd application behaviour ?

• Customer appears coached or cannot explain basic personal or financial details.
• Repeated changes to income, employment, or address information.
• Defensive or unwilling to answer verification questions.

Look out for Forged, altered, or mismatched ID or income documents.

Reluctance to co-operate

• Merchant avoids or reacts defensively when asked for standard AML documents.
• Unwilling to discuss the source of funds or how customers are onboarded.

Identity or Documentation Concerns

• Merchant provides fake or suspicious documentation (e.g., fake addresses).
• You cannot verify their location, ownership, or business operations.

Early loan repayments with unexplained or inconsistent sources of funds.

Overpayments with no clear reason.

Multiple repayments from different accounts.

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