Overview
Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy
Claim Market Ltd Effective Date: May 2026 Version: 1.0
Purpose
Claim Market Ltd (“the Company”) is committed to preventing money laundering, terrorist financing, and all forms of financial crime. Although the Company operates as a lead generation business and does not directly handle client funds or provide regulated financial services, it recognises that its activities may present indirect risks of misuse by individuals or organisations seeking to exploit its platform.
The purpose of this Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) Policy is to establish a comprehensive framework for identifying, assessing, and mitigating those risks. This policy is designed to ensure that the Company operates in a responsible and compliant manner, consistent with applicable legal frameworks, including the UK Money Laundering Regulations 2017 (as amended), the Proceeds of Crime Act 2002, and relevant international standards such as those set by the Financial Action Task Force (FATF).
This policy also supports the Company’s broader commitment to ethical business practices and protects its reputation, partners, and customers from involvement in illicit activity.
Scope
This policy applies to all employees, officers, contractors, consultants, and any third parties acting on behalf of the Company. It covers all business operations, including lead generation activities, onboarding and management of partner firms, marketing campaigns, and any interactions with customers or third parties.
The policy applies globally across all jurisdictions in which the Company operates or targets services, including the United Kingdom.
Policy Statement
The Company adopts a zero-tolerance approach to money laundering and terrorist financing. It will not knowingly engage in, facilitate, or support any activity that may involve the proceeds of crime or contribute to terrorism.
All individuals working for or on behalf of the Company are required to act with integrity and vigilance, and to take reasonable steps to identify and prevent potential financial crime risks. Where any suspicion arises, it must be reported and handled in accordance with this policy.
Nature of Risk in Lead Generation Activities
While the Company does not process or transfer funds, it acknowledges that money laundering and terrorist financing risks may arise indirectly through its operations. These risks include the potential for individuals or companies to misuse lead generation platforms to:
Gain access to regulated financial or legal services under false pretences
Establish relationships with legitimate firms for illicit purposes
Submit fraudulent or misleading information
Use intermediaries to obscure identity or intent
The Company recognises that its role as an introducer places it within the broader ecosystem of regulated industries, including legal services. As such, it maintains proportionate safeguards to prevent its services from being used as a conduit for financial crime.
Risk-Based Approach
The Company adopts a risk-based approach to AML/CTF compliance. This means that resources and controls are applied proportionately based on the level of risk identified in specific activities, relationships, or transactions.
Factors considered in assessing risk include:
The nature and complexity of partner firms
The type of services being promoted (e.g., financial claims)
Geographic risk, including jurisdictions associated with higher financial crime risk
The method of data collection (e.g., affiliate traffic vs. direct enquiries)
Indicators of suspicious or unusual behaviour
This approach ensures that higher-risk areas are subject to enhanced scrutiny while maintaining operational efficiency.
Customer Due Diligence (CDD)
As a lead generation business, the Company does not carry out full Know Your Customer (KYC) checks in the same manner as regulated firms. However, it undertakes proportionate checks to ensure that data collected is consistent, credible, and not indicative of fraudulent or suspicious activity.
This may include reviewing:
The consistency of information submitted through forms
Patterns of repeated or unusual submissions
Indicators of automated or malicious activity
Where concerns arise, the Company may:
Decline to process or share the lead
Flag the data for further review
Escalate internally in accordance with this policy
The Company relies on its partner firms, such as solicitors and CMCs, to conduct full regulatory due diligence and identity verification where required.
Partner Due Diligence
The Company places significant emphasis on the due diligence of third-party partners, recognising that these relationships represent a key area of risk exposure.
Before onboarding a partner, the Company may undertake checks including:
Verification of regulatory status (e.g., SRA or FCA authorisation)
Review of publicly available information, including reputation and history
Assessment of compliance policies and procedures
Confirmation of business legitimacy and operational presence
Ongoing monitoring may also be conducted to ensure continued compliance. The Company reserves the right to suspend or terminate relationships where concerns arise regarding financial crime risk or regulatory compliance.
Monitoring and Detection of Suspicious Activity
Although the Company does not handle financial transactions, it remains vigilant for indicators of suspicious activity that may suggest potential money laundering or terrorist financing risks.
Examples of such indicators may include:
Repeated submissions with inconsistent or fabricated information
Unusual patterns of activity from specific sources or affiliates
Attempts to manipulate or bypass systems
Requests that appear inconsistent with legitimate consumer behaviour
The Company maintains internal processes to review and escalate such concerns where necessary.
Reporting and Escalation
All employees and representatives of the Company are required to report any knowledge or suspicion of money laundering or terrorist financing.
Reports should be made promptly to the designated compliance contact:
Paul Sibley – admin@claim.market
All reports will be treated confidentially and assessed appropriately. Where required, the Company may escalate matters to relevant authorities in accordance with applicable legal obligations.
Record Keeping
The Company maintains appropriate records to support its AML/CTF framework. This includes records of:
Partner due diligence checks
Risk assessments and reviews
Internal reports of suspicious activity
Compliance decisions and actions taken
Records are retained in accordance with the Company’s Data Protection Policy, typically for a period of up to six years.
Training and Awareness
The Company recognises that effective AML/CTF compliance depends on awareness and understanding. Employees and relevant personnel are expected to be familiar with this policy and to understand their responsibilities.
Where appropriate, training or guidance may be provided to ensure that individuals can identify potential risks and respond appropriately.
Governance and Responsibility
The Company maintains internal oversight of AML/CTF compliance through designated roles and responsibilities. The Director is responsible for overseeing the implementation and effectiveness of this policy.
The Director and management are responsible for ensuring that appropriate controls are in place and that the policy is followed across all areas of the business.
Breaches of Policy
Any breach of this policy is taken seriously and may result in disciplinary action, termination of employment or contracts, and, where applicable, legal consequences.
Failure to report known or suspected financial crime may also constitute a breach of this policy.
Review and Updates
This policy will be reviewed periodically to ensure that it remains effective and aligned with legal, regulatory, and business developments. Updates will be made where necessary to reflect changes in risk, operations, or regulatory expectations.
Contact
For any questions or concerns relating to this policy, please contact:
Email: admin@claim.market
Compliance Contact: Paul Sibley - Director