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Anti-Money

Laundering Policy

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Anti-Money Laundering Policy

Introduction

Rush Insurance Services Limited (“Rush Insurance”, “we”, “us”, or “our”) is committed to complying with all applicable anti-money laundering (“AML”), counter-terrorist financing (“CTF”) and financial crime legislation and regulations.

We recognise our responsibility to help prevent money laundering, terrorist financing, fraud and other financial crime and to maintain effective systems and controls designed to identify, assess and mitigate these risks.

This Policy outlines our approach to anti-money laundering compliance and the responsibilities of all individuals acting on behalf of Rush Insurance Services Limited.

What is Money Laundering?

Money laundering is the process by which criminally obtained funds or assets are concealed, transferred or converted to make them appear legitimate.

Money laundering can involve:

  • Concealing the origin of criminal property or funds
  • Assisting others to retain or use criminal proceeds
  • Transferring criminal property through financial systems
  • Using legitimate businesses or products to disguise unlawful activity
  • Financing terrorism or other criminal activity

Legal and Regulatory Framework

Rush Insurance Services Limited complies with all applicable AML and financial crime legislation, including but not limited to:

  • The Proceeds of Crime Act 2002 (“POCA”)
  • The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
  • The Terrorism Act 2000
  • FCA rules and guidance relating to financial crime systems and controls

Under UK law, individuals working within the regulated financial sector are required to report any knowledge or suspicion of money laundering or terrorist financing as soon as reasonably practicable.

Failure to comply with AML legislation may result in criminal penalties, including fines and imprisonment.

Policy Statement

Rush Insurance Services Limited adopts a zero-tolerance approach to money laundering, terrorist financing and financial crime.

We are committed to:

  • Maintaining effective AML systems and controls
  • Conducting business in accordance with legal and regulatory obligations
  • Identifying and reporting suspicious activity
  • Ensuring staff receive appropriate AML training and awareness
  • Taking proportionate, risk-based measures to prevent financial crime
  • Cooperating with regulators and law enforcement agencies where required

As an insurance intermediary, Rush Insurance Services Limited does not generally accept large cash payments and operates within insurer and banking controls designed to mitigate financial crime risk.

Scope

This Policy applies to all employees, directors, contractors, consultants, appointed representatives, outsourced service providers and any other individuals acting on behalf of Rush Insurance Services Limited (collectively referred to as “staff”).

All staff are required to comply with this Policy and applicable AML laws and regulations.

Identifying Suspicious Activity

Staff are expected to remain vigilant to potential indicators of money laundering, terrorist financing or suspicious financial activity.

Examples of suspicious activity may include, but are not limited to:

  • Customers whose identity cannot easily be verified
  • Refusal to provide requested information or documentation
  • Payments received from third parties with no clear connection to the customer
  • Unusual or unexplained payment methods
  • Requests involving foreign bank accounts without a legitimate reason
  • Overpayments followed by requests for refunds to third parties
  • Unusual early cancellation requests
  • Requests for refunds or claims payments to unrelated third parties
  • Complex ownership structures without a clear commercial purpose
  • Customers seeking insurance inconsistent with their known circumstances or financial profile
  • Information suggesting possible criminal activity or sanctions concerns
  • Businesses or transactions where the source of funds cannot reasonably be verified

The presence of one or more indicators does not automatically mean money laundering is taking place; however, concerns must be escalated appropriately.

Reporting Suspicious Activity

Any member of staff who knows, suspects, or has reasonable grounds to suspect money laundering or terrorist financing must report their concerns immediately to:

  • The Compliance Officer; or
  • The nominated Money Laundering Reporting Officer (“MLRO”)

Reports should be made as soon as possible following discovery or suspicion and must not be delayed.

Under no circumstances should staff disclose to the customer or any third party that a suspicion has been raised or that a report may be submitted to authorities. Doing so may constitute the criminal offence of “tipping off”.

Where appropriate, the MLRO will assess the information and determine whether a Suspicious Activity Report (“SAR”) should be submitted to the National Crime Agency (“NCA”).

All decisions and rationale relating to SAR submissions will be appropriately documented.

Systems and Controls

Rush Insurance Services Limited maintains proportionate and risk-based AML systems and controls, including:

  • Staff training and awareness programmes
  • Internal reporting procedures
  • Customer due diligence measures where appropriate
  • Monitoring and escalation procedures
  • Record keeping requirements
  • Financial crime risk assessments
  • Compliance oversight and monitoring

Our controls are designed to reflect the nature, scale and complexity of our business as an insurance intermediary.

Training and Awareness

All relevant staff receive appropriate AML and financial crime training to ensure they:

  • Understand their legal and regulatory responsibilities
  • Can identify suspicious activity indicators
  • Know how and when to escalate concerns
  • Understand confidentiality and tipping-off obligations

Training is reviewed periodically and updated where necessary to reflect legal, regulatory and business changes.

Breach Reporting

Any breach of this Policy, or any concerns regarding practices inconsistent with it, must be reported immediately to the Compliance Officer:

Email: compliance@rushinsurance.co.uk

Failure to comply with this Policy may result in disciplinary action and, where appropriate, referral to regulators or law enforcement authorities.

Policy Review

This Policy will be reviewed at least annually, or sooner where required due to changes in legislation, regulation, business activities or identified risks.

Last updated: May 2026

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