Our approach
Unhectic Limited is a technology services firm. We are not a regulated financial-services entity, we are not authorised by the Financial Conduct Authority, and we do not handle client funds or process payments on behalf of third parties. We are also not in the business of moving money for clients. Even so, we recognise that any business that issues invoices and contracts for material sums can be misused, and we apply controls proportionate to our business to make sure we are not used for money-laundering or sanctions evasion. The controls below are the practical floor — we strengthen them on individual engagements where the risk profile warrants it.
Client onboarding due diligence
Before signing a client engagement we verify three things. First, the client’s legal entity, via Companies House for UK-incorporated entities or the equivalent registry where the client is incorporated abroad. Second, the identity of the person signing the engagement on behalf of the client, normally by reference to a corporate email domain matching the entity, supplemented by a video or in-person introduction. Third, that the source of funds for the engagement is normal commercial revenue of the client’s business. We document the verification on file and refresh it if a material change occurs during the engagement.
Sanctions screening
We screen all new clients and significant suppliers against the consolidated sanctions lists maintained by the principal authorities relevant to our business:
- HM Treasury Office of Financial Sanctions Implementation (OFSI), United Kingdom
- The European Union sanctions list
- The United States Office of Foreign Assets Control (OFAC) Specially Designated Nationals list
- The United Nations Security Council consolidated sanctions list
We do not knowingly enter into commercial relationships with sanctioned individuals or entities, with persons owned or controlled by sanctioned parties, or with parties that act on behalf of sanctioned persons. Where a screening hit appears, we decline the engagement, document the decision, and — where required by law — report the contact to the relevant authority.
Politically Exposed Persons (PEPs)
We screen for Politically Exposed Persons as part of onboarding. Engaging with a PEP, or with a close associate or family member of a PEP, is not prohibited, but it requires senior approval before the engagement is signed and enhanced ongoing oversight during the engagement. The screening is refreshed at each contract renewal.
Suspicious activity
If during the course of an engagement we form a suspicion that money-laundering, sanctions evasion, or another serious financial crime may be taking place — whether involving the client, a counterparty of the client, or a third party that has come to our attention through the work — we will report to the National Crime Agency via the Suspicious Activity Reporting (SAR) regime, as required by the UK Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. We will not tip off the subject of the report; the law specifically prohibits that.
Record-keeping
Onboarding due-diligence records and screening evidence are retained for a minimum of five years from the end of the client relationship, in line with the Money Laundering Regulations 2017. Records of any reported suspicious activity are retained for the same period. Records are stored in our regular business systems with appropriate access controls.
Annual review
This statement is reviewed at least annually by a director, and earlier if our practice or the regulatory environment changes materially. The version banner at the top of this page reflects the current version.