1. Purpose
This policy sets out Murzo Group's approach to high-value goods, anti-money laundering, terrorist financing, proliferation financing, source of funds, source of wealth, customer due diligence, sanctions screening, and suspicious activity escalation.
The purpose is to prevent Murzo Group from being used to launder money, hide criminal proceeds, finance unlawful activity, evade sanctions, disguise ownership, or trade in stolen, illicit, or unlawfully sourced goods.
2. Scope
This policy applies to high-value transactions, cash-sensitive activity, cultural objects, antiques, artworks, fashion and luxury goods, jewellery, precious materials, property assets, vehicles, rare materials, collectibles, food commodities, and other goods or assets that may attract financial crime risk.
It applies to customers, suppliers, agents, intermediaries, auction routes, consultants, brokers, logistics partners, investors, counterparties, beneficial owners, payment parties, and any person acting on behalf of another.
3. Policy Position on High-Value Cash
Murzo Group does not intend to accept or make high-value cash payments unless a director has approved the arrangement and any required money laundering supervision, checks, and controls are in place.
High-value cash includes notes, coins, traveller's cheques, cash deposited into Murzo Group's bank account, or cash paid to a third party for Murzo Group's benefit where the amount reaches or appears structured to avoid applicable thresholds.
4. Risk-Based Due Diligence
Murzo Group will apply due diligence that is proportionate to the value, goods, parties, jurisdiction, payment route, delivery route, ownership structure, and transaction purpose.
- Identify the customer, supplier, counterparty, beneficial owner, agent, and person providing funds where relevant
- Understand the purpose of the transaction and whether it makes commercial sense
- Review source of funds and, where appropriate, source of wealth
- Check sanctions, politically exposed person, adverse media, stolen object, fraud, and cultural property risks where relevant
- Escalate unusual urgency, secrecy, third-party payments, overpayment, complex ownership, shell entities, offshore structures, or reluctance to provide information
5. Enhanced Due Diligence
Enhanced due diligence is required where risk is higher than normal.
- High-value cultural objects, antiquities, artworks, jewellery, precious materials, rare items, or luxury goods
- Transactions involving high-risk jurisdictions, sanctions exposure, conflict zones, politically exposed persons, or complex intermediaries
- Cash, cryptoassets, third-party payments, unusual payment splitting, rapid resale, or payments from unrelated accounts
- Goods with unclear provenance, title, source country permissions, export licences, or authenticity
- Customers or suppliers who avoid identity, ownership, source-of-funds, or transaction-purpose checks
6. Payment Controls
Payments should normally be made through traceable banking channels in the name of the approved customer, supplier, or counterparty.
Murzo Group may reject or delay payments involving cash, cryptoassets, third-party accounts, offshore accounts, unrelated payers, overpayments, refunds to different accounts, payment splitting, or inconsistent transaction details.
7. Suspicious Activity & Escalation
Any worker, contractor, supplier, or representative who suspects money laundering, terrorist financing, sanctions evasion, stolen goods, fraud, false documents, bribery, tax evasion, or illicit trade must escalate the concern promptly.
Murzo Group may pause the transaction, preserve records, seek legal advice, refuse the transaction, make an internal report, submit an external report where required, or cooperate with competent authorities.
8. Training, Awareness & Confidentiality
People involved in high-value transactions should understand financial crime red flags, documentation expectations, payment controls, cultural property risk, sanctions risk, and escalation routes.
Suspicious activity must be handled confidentially. People must not alert a customer, supplier, or counterparty in a way that could prejudice an investigation or breach legal requirements.
9. Records & Retention
Murzo Group will keep records of due diligence, identity checks, beneficial ownership, source-of-funds evidence, source-of-wealth evidence, payment evidence, approvals, risk assessments, screening results, transaction documents, and escalation decisions.
Records must be retained securely and in line with data protection, legal, tax, financial, and audit requirements.
10. Review & Responsibilities
Directors, finance contacts, sales contacts, procurement leads, asset owners, collection custodians, compliance leads, and authorised representatives are responsible for applying this policy.
This policy will be reviewed periodically and when Murzo Group changes products, asset classes, payment methods, jurisdictions, legal duties, or financial crime risk profile.
