Anti Money Laundering

Purpose & Scope:  Pride & Pinion is committed to preventing money laundering and financial crime in all transactions. Although not a regulated financial institution, we acknowledge our obligation to comply with relevant government regulations on AML(Anti Money Laundering) and to implement systems that safeguard against illicit activities. This AML Policy applies to all sales of high-value luxury watches and covers all employees involved in such transactions.

Policy Statement:  We maintain robust procedures to detect and prevent money laundering. Due to the high value of our products, criminals may target luxury watches to launder funds. Pride & Pinion takes active measures to mitigate this risk and will refuse or report any transaction that raises suspicion of money laundering. Each salesperson is responsible for conducting due diligence on their customers, under the oversight of the Managing Director (Stephen Davidson), who serves as the AML compliance officer and has ultimate responsibility for AML oversight.

Customer Due Diligence (CDD): We follow a risk-based approach to customer verification. The level of due diligence is commensurate with the purchase amount and risk profile of the client:

Identification Requirements: For any luxury watch or watch purchase over £1,000, the customer must provide government-issued photographic identification and proof of address. Acceptable forms of ID include a valid passport or driving licence, and proof of address can be a recent utility bill or bank statement (dated within the last 8 weeks). These documents must be supplied within 48 hours of request. This measure is mandatory and helps keep both the business and our customers safe from fraud or money laundering attempts. If identification is not provided or is unsatisfactory, the sale will not proceed.
Transaction Limits & Payment Methods: We impose limits on certain payment types to reduce money-laundering risk. Cash payments are limited to £5,000 per customer per rolling year (in GBP) for in-store purchases. Any larger amounts must be paid through traceable methods. Any single transaction exceeding £5,000 must be completed via bank transfer – high-value online orders above £5,000 will be cancelled and re-initiated via bank transfer in accordance with our High Value Purchasing Policy. We do not accept anonymous or third-party payments; the name on the payment source must match the customer’s identity on file.
Ongoing Monitoring: All transactions are monitored for red flags such as unusual payment patterns, multiple split payments just under verification thresholds, or attempts to evade our ID requirements. Sales staff are trained to be vigilant and to recognise signs of suspicious behaviour (e.g. reluctance to provide ID, structured payments, or inconsistent information). If any transaction or customer behaviour is deemed suspicious, the salesperson must escalate the concern to the Managing Director immediately. Stephen Davidson (MD) will review the details and decide if further action is required, such as enhanced due diligence or filing an official report.
Suspicious Activity Reporting:  Pride & Pinion will report any attempted or confirmed money laundering to the relevant authorities. In the UK, serious suspicions will be reported to the National Crime Agency (NCA) for guidance or filing of a Suspicious Activity Report. We maintain internal records of any such incidents and the actions taken. The Managing Director, as the compliance officer, is responsible for determining when a report to law enforcement is warranted. We reserve the right to cancel any transaction if we believe it may be connected to criminal activity.

Internal Training & Audits:  We recognise that well-trained staff are the first line of defence against money laundering. Pride & Pinion provides comprehensive AML training to all relevant employees at onboarding and through annual refreshers. Training covers how to verify customer identity, detect suspicious patterns, and follow escalation/reporting procedures.

We document all training sessions and require employees to acknowledge understanding of this AML Policy. Management will perform periodic reviews of compliance – for example, spot-checking that proper ID was collected for high-value sales – to ensure the policy is being followed. Any compliance gaps or failures will be addressed with remedial training or disciplinary measures.

Governance & Oversight: The Managing Director (Stephen Davidson) oversees the AML programme. He ensures that the AML Policy is up to date with current laws and best practices, and that all staff understand their responsibilities. While each salesperson conducts customer verification and transaction screening day-to-day, the MD reviews and audits these processes regularly.

The MD also serves as the primary point of contact for law enforcement or regulatory inquiries regarding our AML controls. This policy will be reviewed annually (or more frequently if laws change) to incorporate any new AML regulations or emerging risks in the luxury goods sector.

Policy created: 10 October 2024

Last updated: 9 May 2025

Approved by: Nico Leonard (Company Director)