Anti-Money Laundering & Sanctions Policy.

Vettsafe operates a written Anti-Money Laundering and Sanctions Policy, adopted by the directors of KM GLOBAL CAPITAL LTD (company number 17269549) on 11 November 2026 and reviewed at least every year. The summary on this page describes what it says and what we do. The full policy, and our written risk assessment, are available to lenders, funders and professional advisers on request — email contact@vettsafe.com.

We are a software provider, not a lender or a credit broker. We do not lend money, hold client money, or carry out regulated activity, and we do not rely on any FCA permission or registration. We apply anti-money-laundering controls to our own business as a matter of company discipline, so that the firms we sell to can rely on us as a supplier.

• A written money laundering and sanctions risk assessment, reviewed annually and whenever the service changes.
• Customer due diligence on every prospective customer before an account is opened.
• UK Sanctions List screening of the customer, its directors and its persons with significant control.
• Politically exposed person (PEP) and high-risk jurisdiction checks, with enhanced due diligence where they apply.
• Ongoing monitoring, with re-screening triggered by ownership changes, unusual use, or a sanctions list change.
• Escalation to a Nominated Officer, who decides whether to report to the National Crime Agency.
• A prohibition on tipping off, and a rule that no account decision is taken by one person alone.
• Record keeping for at least five years after a relationship ends.
• Training for everyone who works on onboarding, repeated at least annually.

There is no public sign-up. Every account is opened by a person, not by a form. Before an account is opened we identify the organisation and the individual asking, run a Vettsafe check on the customer itself — Companies House status, officers and persons with significant control — and screen the organisation, its directors and its beneficial owners against the UK Sanctions List.

We ask what the customer intends to check and why, and we only open the account if that is consistent with a legitimate lending or lender-services operation. If we cannot identify who is behind a company, or a sanctions name match cannot be cleared against date of birth, nationality and address, we do not open the account.

Subscriptions are paid by card through a payment provider. We do not accept cash or cryptocurrency. Payment by card means the payer is identified by their card issuer, which is one of the reasons our own channel risk is low.

Everything we decide is recorded: who approved the account, when, on what basis, and what the screening showed.

Our policy is written with regard to the Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Criminal Finances Act 2017, the Sanctions and Anti-Money Laundering Act 2018 and the UK financial sanctions regimes administered by the Office of Financial Sanctions Implementation, the Economic Crime and Corporate Transparency Act 2023, UK GDPR, and the Joint Money Laundering Steering Group guidance. Reports of suspicion go to the National Crime Agency through the UK Financial Intelligence Unit.

The directors own the policy, approve the risk assessment and appoint the Nominated Officer. The Nominated Officer receives internal reports, decides whether a suspicious activity report is filed, and keeps the reporting record. Everyone working at Vettsafe must escalate anything suspicious without delay and must never tip off a customer or a third party.

Vettsafe is appointing a named Nominated Officer. Until that appointment is recorded, internal reports go to the directors at contact@vettsafe.com, who act in that capacity on an interim basis. If you are completing a supplier questionnaire and need the appointed name, ask us and we will tell you the current position.

Vettsafe's checks retrieve and organise information from public registers. That supports your customer due diligence — it helps you see whether a borrower company is live, who controls it, whether a director is disqualified, whether a broker is FCA-authorised, and whether a name appears on the UK Sanctions List.

It does not replace your own duties. Register data is not identity verification, and it does not evidence source of funds or source of wealth. A sanctions name match is an indication that must be verified against date of birth, nationality and address, never an automatic all-clear. Whether and how the Money Laundering Regulations 2017 apply to your firm depends on your own status and activities, and you should confirm that with your money laundering reporting officer or compliance adviser.

We say this on the website, in every guide and in onboarding, because a supplier that overclaims what its product does is a risk to you.

The policy and the risk assessment are reviewed at least every year and after any material change to the service, the law or the business. The Nominated Officer reports to the directors at least annually on accounts opened and declined, screening and reviews completed, internal reports received, and reports filed. A failure to follow the policy is treated as a serious matter and reported to the directors.

Version 1.0 was adopted on 11 November 2026. The next scheduled review is 11 November 2027.