Anti-money laundering policy
Throw is for groups of people who already know each other. We do not hold anyone’s money, but we still take steps to stop Throw being used for money laundering, terrorist financing or to get round sanctions. This policy explains how.
1. Scope
This policy applies to My Task Master Ltd, trading as Throw, and to everyone who works on Throw. It covers money laundering, terrorist financing, proliferation financing and financial sanctions.
Contributions move directly from one member’s bank account to another’s through open banking. Throw never receives, holds or pools contributions. The only money Throw receives is its own fee.
Payments are initiated by Yapily Connect Ltd (FRN 827001), which is authorised by the Financial Conduct Authority and runs its own checks. This policy sits on top of those checks; it does not replace them.
2. Responsibility
Mikael Boecasse is the Money Laundering Reporting Officer (MLRO). The MLRO owns this policy, reviews the risk assessment, decides on anything suspicious and reports to the authorities when required.
You can contact the MLRO at support@mbo9.com with “AML” in the subject line.
3. Our risk assessment
We have assessed the risks of a rotating savings app. The main ones are: a group being used to move money between people who do not really know each other; one person controlling several accounts; unusually large or fast-moving amounts; and members or payees who are subject to sanctions.
Throw is designed to keep those risks low: circles are private and invite-only, there is no public matching of strangers, every payment is made from and to a named UK bank account, and Throw holds no funds.
We review this assessment at least once a year, and whenever we add a new product, country or payment method.
4. Limits we apply today
A circle can have at most 12 members and a contribution can be at most £250. Circles are joined only with an invite from the organiser.
Every contribution is paid from the member’s own bank account and approved in their banking app, so the bank has already confirmed who is paying. When a member connects their bank to receive their pot, their bank also confirms the name on the receiving account.
5. Identity and sanctions checks
We are introducing identity verification with a specialist provider. When it is live, every member will confirm their identity (a photo of an identity document and a short selfie check) before they can pay or receive through Throw, on every plan.
At the same time, every member will be screened against UK and international sanctions lists and politically exposed persons (PEP) lists, and screened again regularly while they use Throw.
The provider keeps the documents and images. Throw keeps only the result of each check and the date it was done.
6. Monitoring
We watch for activity that does not fit how a savings circle normally works, for example amounts or timings out of line with the circle’s agreed schedule, one person linked to many circles or accounts, frequent changes to the account a pot is paid into, or money passing quickly through a member who has just joined.
Changes to the account a pot is paid into are shown to the whole circle, and members are warned before they pay a recently changed account.
7. What we do when something looks wrong
We may ask for more information, pause a member’s account or a circle, refuse or stop a payment instruction, or close an account.
If we know or suspect money laundering or terrorist financing, the MLRO will report it to the National Crime Agency. We will not tell the person concerned that a report has been made, because the law does not allow it.
We will not let anyone use Throw if they, or anyone they pay, are subject to financial sanctions.
8. Records
We keep records of identity check results, payment records, circle activity and any concerns raised for at least five years after a member’s relationship with Throw ends, or longer if the law requires it.
9. Training and review
Everyone who works on Throw reads this policy and is trained to spot and escalate concerns. The MLRO reviews this policy at least once a year and after any significant change to Throw.
10. Raising a concern
If you think someone is using Throw to launder money or to get round sanctions, tell us at support@mbo9.com with “AML” in the subject line. We treat every report in confidence.