Effective Date: 28^th May 2025

Last Reviewed: 28^th May 2025

1. Purpose

The purpose of this Anti-Money Laundering (AML) Policy is to ensure that Red Holidays Ltd (“the Company”) complies with all applicable laws and regulations in the UK relating to the prevention of money laundering and terrorist financing.

This policy outlines our commitment to preventing the use of our business for money laundering purposes and establishes the procedures we follow to detect and report suspicious activity.

2. Scope

This policy applies to:

• All employees, consultants, and contractors of Red Holidays Ltd
• All clients, agents, and third parties associated with Red Holidays Ltd
• All business activities, including the sale of travel packages, tickets, accommodation, and related services

3. What is Money Laundering?

Money laundering is the process of concealing the origin of funds obtained through illegal means, typically by passing them through a complex sequence of banking transfers or commercial transactions. It is a criminal offence under UK law.

Examples of money laundering include:

• Purchasing high-value services with criminal proceeds
• Structuring payments to avoid reporting thresholds
• Using third parties to disguise the true source of funds

4. Our Legal Obligations

Under UK AML laws and regulations, Red Holidays Ltd is required to:

• Identify and verify the identity of customers (Know Your Customer or KYC)
• Conduct due diligence and enhanced due diligence where necessary
• Keep appropriate records of all transactions and checks for a minimum of 5 years
• Report any suspicious activity to the National Crime Agency (NCA)
• Appoint a Nominated Officer (MLRO) responsible for AML compliance

5. Know Your Customer (KYC) & Due Diligence

We carry out due diligence on customers by:

• Collecting and verifying full names, addresses, and contact details
• Obtaining identification documents (e.g., passport or driver’s licence) for high-value transactions
• Understanding the nature and purpose of the transaction
• Checking the source of funds when appropriate

Enhanced due diligence will be applied in situations where there is a higher risk of money laundering (e.g., large cash payments, clients from high-risk countries).

6. Acceptable Payment Methods

To reduce the risk of money laundering, Red Holidays Ltd will:

• Prefer electronic payments via secure banking systems
• Limit acceptance of cash payments
• Not accept payments from unrelated third parties without documented justification
• Refuse to process transactions that appear suspicious or inconsistent with the customer’s known profile

7. Suspicious Activity Reporting (SAR)

Employees must report any suspicious transactions or behaviours to the Money Laundering Reporting Officer (MLRO) without delay. The MLRO will assess whether a Suspicious Activity Report (SAR) should be submitted to the National Crime Agency (NCA).

Common red flags include:

• Reluctance to provide identification
• Inconsistencies in the source of funds
• Transactions involving unusually large amounts of money
• Clients from jurisdictions with weak AML controls

8. Training & Awareness

All staff will receive appropriate AML training:

• Upon joining the company
• At regular intervals thereafter
• Whenever significant changes to AML laws or internal procedures occur

9. Record Keeping

We are required to retain records of:

• Customer identification and verification
• Payment details
• Copies of all due diligence documents
• Communications and internal SARs

These records will be retained for at least 5 years from the end of the business relationship or transaction.

10. Policy Governance

The MLRO is responsible for:

• Overseeing implementation of the AML Policy
• Monitoring compliance
• Conducting internal audits and risk assessments
• Reporting to the NCA when appropriate

MLRO Contact Details:
Name: Amanda Doherty
Email: amanda@redholidays.travel
Phone: +44 1639 720424

11. Breaches of Policy

Failure to comply with this policy may result in:

• Disciplinary action, including termination of employment
• Civil or criminal prosecution under the UK Proceeds of Crime Act 2002

12. Review and Updates

This policy is reviewed annually or as required by changes in legislation or company activities.