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Anti-Money Laundering Policy

Effective: 1 July 2026 · Version 1.0

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1. Our Commitment

LagomFA Ltd is committed to preventing money laundering, terrorist financing, and financial crime in all forms. Although we are not formally supervised under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, we voluntarily adopt the principles of those regulations as a matter of good governance and business integrity.

We recognise that the energy sector, including data and advisory services, can be exposed to financial crime risk. This policy sets out the standards we apply to protect LagomFA Ltd, our clients, and the integrity of the markets in which we operate.

Clare MacGregor, Managing Director, acts as the designated person responsible for AML compliance within LagomFA Ltd.

2.  What We Will Not Do

LagomFA Ltd will not knowingly:

  • Engage with clients, counterparties, or third parties where there is reasonable suspicion of money laundering or terrorist financing

  • Accept payments from unknown or unverified sources

  • Facilitate transactions designed to conceal the origin of funds

  • Enter into business relationships where the beneficial ownership of a client entity cannot be established

  • Engage with individuals or entities subject to UK, EU, or UN sanctions

3. Client Due Diligence

Before entering into a new client relationship, we will take reasonable steps to verify the identity of the client and, where applicable, the beneficial owner. This includes:

  • Confirming the legal identity and registration of corporate clients

  • Understanding the nature and purpose of the business relationship

  • Identifying the source of funds where relevant to the services provided

  • Applying enhanced scrutiny to clients or transactions that present higher risk

  • Applying enhanced due diligence to any relationship involving a Politically Exposed Person (PEP) or their close associates

We reserve the right to decline or terminate a business relationship where due diligence cannot be completed to our satisfaction. Client due diligence records will be retained for a minimum of five years.

4. Reporting Suspicions

Any director or member of staff who suspects that money laundering or terrorist financing is occurring must report this immediately to the Managing Director. Reports will be handled confidentially and in accordance with applicable law. Concerns can be reported by email to hello@lagomfa.com.

We will never tip off a client or third party that a report has been made or that an investigation is underway, as doing so may constitute a criminal offence.

5. Review

This policy will be reviewed annually and updated as required to reflect changes in legislation, guidance, or our business activities.

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