Anti-Money Laundering Policy

Version 2.0. Effective 31 July 2026. Next review 31 July 2027.

1. Purpose and scope

This policy sets out how Auren Institute prevents its business being used for money laundering or terrorist financing, and what anyone working for us must do if they suspect it.

Auren Institute is registered in Malta at 92, No. 1, St Edward Street, Qormi QRM 2136, Malta, registration P1421, VAT MT20967027. We operate in Malta and the United Kingdom, so this policy addresses the law of both.

It applies to every payment we receive and every commercial relationship we enter, including corporate clients, partners, resellers, sponsors and affiliates.

2. Our regulatory position, stated plainly

Auren Institute is a training and education provider. On our current activities we are not a relevant person under the United Kingdom Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and not a subject person under the Maltese Prevention of Money Laundering and Funding of Terrorism Regulations, Subsidiary Legislation 373.01.

We adopt this policy voluntarily. We do so because we teach anti-money laundering compliance to regulated firms, and because the general criminal offences below apply to every business regardless of supervision.

If our activities change so that we become a relevant or subject person, this policy is not sufficient on its own and must be replaced with a supervised-sector framework including customer due diligence, a written risk assessment and a registered nominated officer.

3. The law we work to

• United Kingdom: Proceeds of Crime Act 2002, in particular the principal money laundering offences at sections 327 to 329 and the failure to disclose offences at sections 330 to 332.
• United Kingdom: Terrorism Act 2000, sections 15 to 18.
• Malta: Prevention of Money Laundering Act, Chapter 373 of the Laws of Malta.
• Malta: Prevention of Money Laundering and Funding of Terrorism Regulations, Subsidiary Legislation 373.01, and guidance issued by the Financial Intelligence Analysis Unit.
• Both jurisdictions: applicable financial sanctions regimes.

4. What we will not do

• Accept cash in any amount for any product or service. All payments are by bank transfer or card through our payment provider.
• Accept payment from a third party unconnected to the learner or the contracting organisation, unless the connection is explained and documented.
• Accept payment from a jurisdiction subject to financial sanctions, or from any person or entity appearing on an applicable sanctions list.
• Refund a payment to a different account or person from the one that paid it.
• Enter a partnership, reseller or introducer arrangement without knowing who owns and controls the counterparty.

5. Warning signs

Anyone dealing with a client or partner should stop and escalate if they see any of the following.

• Reluctance to provide basic identifying information about the organisation.
• Payment offered from an unexpected jurisdiction, entity or individual.
• Overpayment followed by a request for a refund of the difference.
• A request to invoice a different entity from the one receiving the training.
• Urgency or pressure to bypass our normal onboarding or invoicing.
• An arrangement that makes no commercial sense for the counterparty.

6. Reporting a suspicion

Report immediately to the Managing Director at info@aureninstitute.com. Put it in writing. Do not investigate it yourself.

Do not tell the client, the partner or anyone else that a report has been made. Doing so may amount to the criminal offence of tipping off under section 333A of the Proceeds of Crime Act 2002 and the equivalent Maltese provisions.

The Managing Director decides whether an external report is required, and to whom. In Malta that is the Financial Intelligence Analysis Unit. In the United Kingdom that is the National Crime Agency.

No one who makes a report in good faith will suffer any detriment for doing so, even if the suspicion turns out to be unfounded.

7. Records

We keep records of client and partner identity, payments received, and any report made under this policy, for five years from the end of the relationship. Records of a report and the decision taken are kept by the Managing Director separately from the client file.

8. Training

Everyone acting for Auren Institute completes anti-money laundering awareness training on joining and at least every two years afterwards. Completion is recorded.

Ownership and review

This policy is owned by the Managing Director of Auren Institute and applies to all directors, employees, contractors, associate trainers and anyone acting for Auren Institute.

It is reviewed annually, and sooner if the law changes, if an incident occurs, or if our operations change materially. The version and effective date are shown at the top of this page.

Questions about this policy, and any report made under it, go to info@aureninstitute.com, marked for the attention of the Managing Director.