Approved by Raymond Cullen, Managing Director — next review January 2027

Anti-Money Laundering Policy

Cullen Utilities Ltd takes a zero-tolerance approach to money laundering and financial misconduct.

Money laundering is the process by which the proceeds of crime are disguised to appear legitimate. Schemes range from the very simple to the highly complex and are typically made up of three stages: placement (introducing illicit money into the system), layering (moving money around to disguise its origin) and integration (money re-entering the system through apparently clean investment).

As an organisation we are committed to an ethical code of conduct and adopt a zero-tolerance approach to financial misconduct, including money laundering. This includes not concealing, disguising, converting or transferring criminal property or removing it from the UK; not entering into or becoming concerned in an arrangement known or suspected to facilitate the acquisition, retention, use or control of criminal property; and not acquiring, using or possessing criminal property.

How we comply

This policy applies to all members of our organisation, and any breach may result in disciplinary procedures and potentially dismissal. To adhere to this policy we will:

  • Appoint a Money Laundering Reporting Officer.
  • Maintain suitable and sufficient records of all transactions.
  • Report any suspicious activity promptly and efficiently.
  • Carry out checks on customers to confirm their credibility.
  • Carry out, and adhere to, an anti-money laundering risk assessment.
  • Provide information, instruction and training on anti-money laundering procedures.
  • Maintain customer due diligence at all times.

We take all necessary steps to comply with anti-money laundering regulations and implement best practice wherever possible.