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​Client Care Policy

1. Introduction
We are committed to providing high-quality, professional, and transparent services to all clients. This Client Care Policy sets out the standards clients can expect from our firm and how we ensure a positive and fair working relationship.

2. Communication
We aim to communicate clearly and promptly. We will confirm in writing the services we provide, explain any changes, and keep clients updated on work progress and any delays.

3. Confidentiality
Client information is treated as strictly confidential and will not be disclosed to any third party without prior consent, unless required by law or regulation.

4. Quality of Service
We strive to maintain the highest standards of service. Our team undergoes continuous professional development to remain current and compliant with all legal and regulatory standards.

5. Complaints
We aim to resolve any concerns as quickly and professionally as possible. If a client is dissatisfied with any aspect of our service, they should raise the matter in writing to the firm’s principal, [Vitaliy Astakhov].
We will acknowledge the complaint within 5 working days and aim to investigate and provide a full response within 14 days. If we cannot resolve the issue, the client may escalate the matter to the Association of Accounting Technicians (AAT).

6. Disengagement
Should either party wish to terminate the engagement, we will provide reasonable notice in writing and ensure a smooth transition. We will inform clients of any outstanding work and fees. If disengagement is initiated due to a conflict of interest, non-cooperation, or ethical concerns, a summary of reasons will be documented and shared where appropriate.

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Continuity of Practice Policy

1. Purpose
This policy ensures continuity of service to clients in the event that [Vitaliy Astakhov], as the licensed accountant, becomes temporarily or permanently unable to practice due to illness, incapacity, death, or other unforeseen circumstances.

2. Nominated Continuity Accountant
We have a written agreement with [Full Name of Continuity Accountant], an AAT Licensed Accountant, to take over client files and urgent duties if necessary.
The continuity accountant is authorised and competent in the areas of practice offered by this firm.

3. Scope and Responsibilities
The continuity accountant will:

• Secure and maintain access to client records

• Fulfil urgent statutory deadlines (e.g., tax returns, VAT, payroll)

• Communicate clearly with all affected clients

• Maintain confidentiality and data protection obligations

• Notify AAT as appropriate

4. Client Communication
Clients will be informed as soon as possible about the implementation of this policy and the identity of the continuity accountant, unless this would breach legal or regulatory restrictions.

5. GDPR and Legal Compliance
The agreement and any resulting transfer of information comply with the General Data Protection Regulation (GDPR) and relevant data protection laws.

6. Review
This policy and agreement will be reviewed annually, or upon any change in the practice structure or nominated continuity accountant.

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Anti-Money Laundering (AML) Procedures

1. Introduction
These procedures outline the steps taken by our firm to ensure compliance with the Money Laundering Regulations 2017 (as amended), Proceeds of Crime Act 2002, and related legislation. All staff must adhere strictly to these procedures.

2. Risk Assessment
We conduct a firm-wide risk assessment annually, or sooner if there is a significant change in operations. The assessment considers:

• Nature, scale, and complexity of services offered

• Geographic risk

• Types of clients

• Delivery channels (face-to-face, remote, etc.)

• Client base risk profile (e.g., PEPs, high-net-worth individuals, high-risk sectors)

3. Customer Due Diligence (CDD) CDD is performed:

• Before establishing a business relationship

• When conducting an occasional transaction

• If money laundering is suspected

• If information previously collected is inadequate or has changed

3.1 Standard CDD Requirements
Obtain and verify:

• Full name and date of birth

• Residential address

• Photo ID (e.g., passport, driving licence)

• Proof of address (e.g., utility bill, bank statement)

3.2 Enhanced Due Diligence (EDD)
EDD is required where there is:

• A high-risk client

• A Politically Exposed Person (PEP)

• A client based in a high-risk third country

• An unusual or complex transaction

• False or stolen documentation

4. Ongoing Monitoring We conduct ongoing monitoring of:

• Transactions to ensure consistency with the client profile

• Changes in ownership, structure, or business model

• Expiry of identification documents

• Unusual behaviour or transactions

5. Record Keeping All records related to CDD, risk assessment, and monitoring will be retained for 5 years after the end of the client relationship or the date of an occasional transaction. These records will then be securely deleted or destroyed.

6. Training All relevant staff receive AML training:

• At induction

• Annually thereafter

• Whenever regulations or risks change

Training covers:

• Legal responsibilities

• Recognising red flags

• Internal reporting procedures

7. Reporting Suspicious Activity If a staff member suspects money laundering:

• Report immediately to the Money Laundering Reporting Officer (MLRO)

• The MLRO will assess the concern and, if required, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA)

8. Tipping Off It is a criminal offence to inform a client that a SAR has been made or an investigation is underway. All staff are trained to avoid tipping off.

9. Independent Audit Function If proportionate to the size and nature of the firm, an independent audit will be conducted annually to assess compliance and recommend improvements.

10. Review and Update These procedures will be reviewed at least annually and updated as necessary to reflect changes in regulation, guidance, and internal processes.