Anti-Money Laundering (AML) Policy

Introduction

Balloch & Co Ltd is committed to preventing money laundering, terrorist financing, fraud, and other financial crimes.

We maintain policies and procedures designed to identify, assess, and mitigate the risks associated with financial crime. This policy outlines our approach to customer due diligence, identity verification, transaction monitoring, and compliance obligations.

Our Commitment

Balloch & Co will not knowingly engage in business with individuals or organisations involved in:

Money laundering
Terrorist financing
Fraud
Identity theft
Sanctions evasion
Criminal activity
Tax evasion
Corruption or bribery

We reserve the right to refuse, suspend, delay, or terminate any transaction where concerns arise regarding financial crime or regulatory compliance.

Customer Due Diligence (CDD)

To help prevent financial crime, we may conduct Customer Due Diligence (“CDD”) before completing a transaction.

Customers may be required to provide:

Identity Verification

Full legal name
Date of birth
Residential address
Government-issued photo identification

Proof of Address

A document dated within the previous three months, including:

Utility bill
Bank statement
Council tax statement
Government correspondence

Biometric Verification

Where appropriate, customers may be required to provide a live selfie or facial verification image.

Identity Verification Provider

Balloch & Co uses Sumsub to assist with identity verification and fraud prevention procedures.

Sumsub may be used to:

Verify identity documents
Validate customer identity
Detect document fraud
Perform biometric verification
Support compliance and risk assessments

Verification may be required before a transaction is approved.

Enhanced Due Diligence (EDD)

In higher-risk situations, Balloch & Co may conduct Enhanced Due Diligence.

Additional information may be requested, including:

Source of funds
Source of wealth
Additional identification documents
Information regarding the purpose of the transaction
Supporting documentation relating to ownership of a watch

EDD may be applied where:

Transaction values are significant
Unusual transaction patterns are detected
Higher-risk jurisdictions are involved
Additional risk indicators are identified

Transaction Monitoring

We monitor transactions and customer activity for indicators of suspicious behaviour, including:

Unusual payment patterns
Multiple linked transactions
Inconsistent customer information
Requests involving third parties without clear justification
Attempts to avoid verification requirements
Transactions that appear inconsistent with the customer’s profile

Where concerns arise, transactions may be delayed while further reviews are conducted.

Sanctions Screening

Balloch & Co may conduct sanctions and compliance screening against applicable UK, international, and regulatory watchlists.

We reserve the right to refuse transactions involving sanctioned individuals, organisations, or jurisdictions.

Source of Funds

For certain transactions, Balloch & Co may request evidence demonstrating the legitimate source of funds used for a purchase.

Examples may include:

Bank statements
Proof of salary or employment
Sale agreements
Inheritance documentation
Business income records

Failure to provide satisfactory evidence may result in cancellation of the transaction.

Suspicious Activity

Where suspicious activity is identified, Balloch & Co may:

Suspend the transaction
Request additional information
Conduct further compliance checks
Decline the transaction
Take any action required by applicable law

We may not be permitted to disclose the reasons for certain compliance-related decisions.

Record Keeping

Balloch & Co may retain identity verification and transaction records for a period required by applicable law, regulatory obligations, fraud prevention requirements, and legitimate business purposes.

Records are stored securely and access is restricted to authorised personnel.

Data Protection

All personal information collected for AML and compliance purposes is processed in accordance with our Privacy Policy and applicable UK data protection laws, including the UK GDPR and the Data Protection Act 2018.

Customer Cooperation

Customers agree to:

Provide accurate information
Submit genuine and unaltered documents
Cooperate with verification requests
Promptly provide any additional information reasonably requested

Failure to comply may result in delays, suspension, or cancellation of transactions.

Contact

For AML, compliance, or verification enquiries, please contact:

Balloch & Co Ltd

Email: compliance@ballochco.com

Telephone: 020 3355 7555

Registered Office:

Signature by Regus
2nd Floor, Berkeley Square House
Berkeley Square
London
W1J 6BD
England

Shop menus

Brands