Anti-Money Laundering (AML) Policy

Skinny Wrists Ltd trading as Metal Clay

Effective date: August 2026
Review date: August 2027

1. Purpose

Skinny Wrists Ltd trading as Metal Clay is committed to conducting its business responsibly and taking reasonable measures to prevent the business from being used for money laundering, terrorist financing, fraud or other financial crime.

This policy sets out the procedures followed by the company and its employees to identify and manage potential financial crime risks.

2. Nature of Our Business

Metal Clay is a UK-based retailer and wholesaler of metal clay, jewellery-making materials, tools, equipment and associated products.

The company sells products to retail customers, trade customers and other businesses through online and other approved sales channels.

The company also purchases stock, tools and jewellery-making supplies from UK and international manufacturers and suppliers. Consequently, the company may make legitimate international business payments and use regulated currency and foreign-exchange providers to facilitate these payments.

3. Payment Policy

Metal Clay does not accept cash payments.

Approved customer payment methods include:

• Debit and credit card payments

• Bank transfers

• Approved online/electronic payment methods

The company will not accept cash payments of any value as an alternative to the approved payment methods above.

In particular, the company will not accept cash payments of £10,000 or more, whether as a single payment or as a series of linked payments.

Cash deposits directly into the company's bank account are not an approved payment method and should be investigated if received unexpectedly.

4. Source of Business Funds

Funds used by Skinny Wrists Ltd for supplier payments, stock purchases and foreign currency transactions are derived from legitimate business activities.

These principally comprise revenue received from the retail and wholesale sale of products and other legitimate company funds.

Business income is received through established banking and payment channels and recorded through the company's accounting and financial records.

Payments to suppliers are made from company funds through recognised banking, card payment or regulated payment/foreign-exchange channels.

The company does not use cash to fund foreign currency transactions or international supplier payments.

5. International Payments and Foreign Exchange

Skinny Wrists Ltd purchases products and supplies from manufacturers and suppliers outside the United Kingdom and therefore has a legitimate business requirement to purchase foreign currencies and make international payments.

Foreign currency transactions are undertaken for genuine commercial purposes, primarily to pay invoices for stock, products, equipment and supplies purchased by the company.

Where appropriate, the company retains supporting documentation such as supplier invoices, purchase orders, order confirmations and other relevant commercial records.

The company does not knowingly process payments on behalf of unrelated third parties or use its foreign-exchange facilities for personal transactions unrelated to the company's business.

6. Supplier Due Diligence

The company seeks to deal with legitimate manufacturers, distributors and suppliers.

Before establishing significant new supplier relationships, reasonable steps may be taken to confirm the identity and legitimacy of the supplier.

These may include reviewing:

• Company or trading details

• Supplier websites and contact information

• Invoices and purchase documentation

• Bank/payment details

• Previous trading history or correspondence

• Relevant company registration information, where appropriate

Payments should normally be made to an account held in the name of the supplier or contracting entity.

Requests to make payments to an unrelated third party or an unexpected bank account should be independently verified before payment is authorised.

Changes to established supplier bank details should also be verified before payment.

7. High Value Dealer Status

The company does not currently operate as a High Value Dealer because it does not make or receive qualifying high-value cash payments in connection with the sale or purchase of goods.

The company will review its regulatory obligations before introducing or making qualifying cash payments.

8. Customer and Transaction Monitoring

Employees should remain alert to unusual or suspicious transactions.

Examples may include:

• Unusually large or unexplained payments.

• Payments from unrelated third parties without reasonable explanation.

• Requests for refunds to accounts different from the original payment source.

• Unusual ordering or payment patterns.

• Attempts to circumvent normal payment procedures.

• Transactions involving individuals, organisations or jurisdictions subject to applicable UK financial sanctions.

The presence of one of these factors does not necessarily indicate criminal activity but should prompt further consideration where appropriate.

9. Wholesale and Trade Customers

Where appropriate and proportionate, the company may obtain information about wholesale, reseller or other business customers, including business name, address, contact details, company number, VAT number and relevant payment information.

Additional information may be requested where a transaction appears unusual or presents an increased financial crime risk.

10. Refunds

Where reasonably possible, refunds will be returned using the original payment method.

Requests to refund money to an unrelated third party, alternative bank account or substantially different payment method should be investigated before the refund is processed.

11. Financial Sanctions

The company will comply with applicable UK financial sanctions.

Where a customer, supplier, transaction or destination raises concerns, appropriate checks will be undertaken before proceeding.

The company will not knowingly make funds or economic resources available to a person or organisation where doing so would breach applicable UK sanctions.

12. Suspicious Activity

Employees must report unusual or suspicious activity to the person responsible for AML/financial crime compliance within the company.

Employees should not accuse a customer or supplier of money laundering or other criminal activity.

The company will consider the circumstances and determine whether further investigation, professional advice or reporting to an appropriate authority is required.

13. Record Keeping

The company maintains appropriate business records relating to orders, invoices, payments, refunds, customers and suppliers in accordance with its legal, accounting and regulatory obligations.

Records relating to international supplier payments may include supplier invoices, purchase orders, payment confirmations and associated correspondence.

Where additional checks are undertaken because of a financial crime concern, an appropriate record should be retained of the checks undertaken and the decision reached.

14. Staff Responsibilities

Relevant employees should be familiar with:

• The company's no-cash policy.

• Approved payment methods.

• Procedures for supplier payments.

• Warning signs associated with unusual transactions.

• Procedures for escalating concerns.

• The importance of verifying unexpected changes to supplier payment details.

Any concerns should be escalated promptly to the person responsible for AML/financial crime compliance.

15. Responsibility

Overall responsibility for this policy rests with the directors of Skinny Wrists Ltd.

Responsible person: Jemma Woods
Position: Director
Date approved: 04/08/2026
Signature: J. Woods

16. Review

This policy will be reviewed at least annually and sooner where:

• The company's payment methods change.

• The nature or scale of the business changes significantly.

• The company enters substantially different markets or territories.

• There is a significant change to the company's international supplier arrangements.

• Relevant legislation or regulatory guidance changes.

If the company considers accepting or making high-value cash payments in the future, its obligations under the UK's Money Laundering Regulations and HMRC registration requirements will be reviewed before such payments are permitted.