1. PURPOSE AND SCOPE
This Anti-Money Laundering (“AML”) Policy describes the measures taken by MORVEX CORPORATION LIMITED (Company Registration No: 17034959), trading as totumskill.com, to prevent the use of our Services for money laundering, terrorist financing or other financial crime.
This policy applies to all transactions processed through totumskill.com and to all employees, contractors and agents of MORVEX CORPORATION LIMITED.
2. APPLICABLE LAW
We comply with applicable United Kingdom and European Union laws on the prevention of money laundering and terrorist financing, including:
- The Proceeds of Crime Act 2002 (POCA);
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) as amended;
- The Terrorism Act 2000 and the Counter-Terrorism Act 2008;
- The Sanctions and Anti-Money Laundering Act 2018;
- The EU Sixth Anti-Money Laundering Directive (6AMLD) where applicable to our cross-border activities.
3. RISK-BASED APPROACH
We adopt a risk-based approach. Each transaction is assessed for money laundering and terrorist financing risk based on:
- Customer profile and geographic location;
- Transaction amount, frequency and pattern;
- Payment method and source of funds;
- Product or service purchased (digital educational courses).
4. CUSTOMER DUE DILIGENCE (CDD)
We carry out customer due diligence in line with MLR 2017. For each purchase we collect, at a minimum:
- Customer name and email address;
- Billing country (collected by our payment service provider for fraud prevention);
- IP address and device fingerprint at the time of purchase;
- Last 4 digits of the payment card and authorisation token (we do not store full card details — see our Privacy Policy §6).
Enhanced due diligence (“EDD”) is applied where: (a) the transaction value exceeds £10,000 in aggregate over a rolling 12 months; (b) the customer is located in a high-risk jurisdiction; (c) the transaction pattern is unusual; or (d) any other indicator of elevated risk is present. EDD may include requests for additional identification, source-of-funds evidence or commercial purpose statements.
5. SANCTIONS SCREENING
Every transaction is screened against the consolidated UK financial sanctions list maintained by the Office of Financial Sanctions Implementation (OFSI), the EU consolidated list, the United Nations Security Council list and the United States OFAC SDN list.
We do not knowingly process transactions originating from, or destined for, sanctioned individuals, entities or jurisdictions. Currently restricted jurisdictions include (without limitation) Iran, Democratic People’s Republic of Korea, Syria, Cuba, Crimea, Donetsk and Luhansk regions, Belarus and the Russian Federation, in addition to any other jurisdiction added to applicable sanctions lists.
Transactions that match a sanctions list are blocked. Where required, suspicious activity reports (SARs) are filed with the UK National Crime Agency (NCA).
6. SUSPICIOUS ACTIVITY REPORTING
Our Money Laundering Reporting Officer (MLRO) is responsible for receiving internal disclosures of suspicious activity, evaluating them, and filing Suspicious Activity Reports with the UK National Crime Agency under POCA / Terrorism Act 2000.
Indicators that may trigger an internal report include: unusual transaction patterns; mismatch between billing country and IP location; use of disposable email or fraud-prone payment instruments; refusal to provide CDD information when requested; or any other circumstance that, in the reasonable opinion of the MLRO, suggests money laundering or terrorist financing.
7. RECORD KEEPING
We retain CDD records, transaction records, and SAR-related documentation for a minimum of five (5) years from the end of the customer relationship or the date of the transaction, in line with MLR 2017 requirements.
8. EMPLOYEE TRAINING
All employees and contractors who handle customer transactions receive regular training on this policy, sanctions screening procedures, recognition of suspicious activity and reporting obligations. Training is refreshed at least annually and on material changes to applicable law.
9. MLRO AND COMPLIANCE CONTACT
Money Laundering Reporting Officer:
MORVEX CORPORATION LIMITED
Studio No. 28, 2 Old Brompton Road, London, England, SW7 3DQ
Company Registration No: 17034959
Email: info@totumskill.com
Phone: +44 7893 930806
Reports filed under POCA / Terrorism Act 2000 are submitted to the UK National Crime Agency through the SAR Online portal.
10. POLICY REVIEW
This AML Policy is reviewed at least annually and updated to reflect changes in applicable law, regulatory guidance, and our risk environment.
Last updated: 14 May 2026