AUTOHORN FLEET SERVICES LTD (trading under various brand names including Flexed and Clear Car Leasing) (“Autohorn”) is committed to preventing money laundering, fraud, bribery, corruption and other forms of financial crime across all areas of its operations.
Autohorn operates a zero-tolerance approach to financial crime and maintains proportionate policies, procedures and internal controls designed to prevent, detect and respond to financial crime risks, in line with applicable UK legislations.
2. Regulatory Framework
Autohorn’s policies and procedures are aligned with, and informed by, the following legislation and guidance (as amended):
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Economic Crime and Corporate Transparency Act 2023
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Proceeds of Crime Act 2002
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Terrorism Act 2000
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Bribery Act 2010
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Money Laundering Regulations 2017
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FCA Handbook (where applicable)
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Joint Money Laundering Steering Group (JMLSG) Guidance
3. Scope & Application
This policy applies to:
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All employees, contractors, agency staff and representatives
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All business activities conducted under Autohorn brands
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Relationships with suppliers, partners and customers
Failure to comply with this policy may result in disciplinary action and/or termination of contractual relationships.
4. Fraud & Financial Crime Risk Management (ECCTA)
In accordance with current policies, Autohorn has implemented reasonable prevention procedures to mitigate the risk of fraud committed by persons associated with the organisation.
These procedures are risk-based and proportionate to the nature, size and complexity of Autohorn’s operations and include:
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Senior management oversight of financial crime risk
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Clear allocation of responsibility for fraud and AML controls
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Risk assessments covering fraud, AML and terrorist financing
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Internal controls designed to prevent misuse of funds, false representation, and facilitation of fraud
5. Key Controls & Mitigation Measures
Autohorn mitigates financial crime risk through the following measures:
5.1 Due Diligence & KYC
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Customer and supplier identification and verification procedures
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Risk-based due diligence proportionate to transaction size and risk
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Enhanced checks where higher risk indicators are identified
5.2 Financial Controls
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Segregation of duties
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Approval thresholds and authorisation controls
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Traceable and auditable transaction records
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Restrictions on cash transactions
5.3 Supplier & Third-Party Risk
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Appropriate due diligence on suppliers and partners
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Contractual expectations regarding ethical conduct and compliance
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Ongoing monitoring where required
5.4 Monitoring & Review
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Ongoing monitoring of customer and supplier relationships
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Periodic review of controls and risk assessments
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Annual rolling reviews of active accounts
6. Reporting & Escalation
Autohorn maintains procedures to enable the prompt reporting of suspected money laundering, fraud or financial crime.
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Suspicious Activity Reports (SARs) are submitted to the National Crime Agency (NCA) where required
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A Money Laundering Reporting Officer (MLRO) is appointed where legally or regulatorily required
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Records relating to due diligence and reporting are retained for a minimum of five years
7. Training & Awareness
All relevant staff receive training on money laundering, fraud and financial crime risks relevant to their role.
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Training covers applicable legal and regulatory requirements, common risk indicators and potential methods of financial crime.
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Staff are instructed on how to identify, escalate and report suspected suspicious activity in accordance with internal procedures.
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Training is delivered on a role-appropriate basis and refreshed periodically to reflect changes in legislation, guidance and risk.
8. Governance & Responsibility
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Senior management is responsible for oversight of financial crime controls
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The Compliance Officer / MLRO is responsible for implementation and reporting
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All staff are required to act ethically and report concerns immediately
