Kin Cooperative is a registered Co-operative Society under the Co-operative and Community Benefit Societies Act 2014. Kin is not a financial institution or money service business and does not provide payment services by way of business.
Kin Cooperative is committed to preventing its platform and services from being used for money laundering or terrorist financing. This policy ensures that Kin meets its obligations under the Proceeds of Crime Act 2002 (POCA) and related UK legislation, while upholding cooperative principles of trust, transparency, and mutual responsibility.
All Kin Cooperative members are required to adhere to this policy.
Member Verification
We employ a risk-based approach to verify our members' identities:
- Members are required to register with a verified email address.
- Members’ financial contributions must be made from a verified UK bank account in the member’s name.*
- We reserve the right to request formal identification, such as a passport or UK driver’s licence, at any time, particularly if a transaction is flagged for review. Accounts may be suspended pending verification.
*We understand there are instances where individuals may choose to use a different name (for example, for safety or personal reasons). In these cases, Kin may request proof of identity in confidence to fulfil its obligations. Identity information will be stored securely and not shared without authorisation unless there is a suspicion of criminal activity.
Mutual Aid Purpose
- For each new group (Mutual Aid Club) we ask the creator to describe its intended purpose to ensure it aligns with Kin’s values and financial mutual aid policies.
- Transaction size and volume will be monitored to ensure they are consistent with stated mutual aid purposes and that groups are not being used for business or profit.
- Where a group’s activity or purpose changes, the Money Laundering Reporting Officer (MLRO) may request updated information to confirm continued alignment.
Transaction monitoring and limits
The following limits are set for any single member:
- £5,000 per single transaction
- £5,000 per rolling 30 day period
- £25,000 per rolling 365 day period
Transactions exceeding these limits will be automatically flagged for review by the MLRO and may be suspended and subject to review. The MLRO may request supporting information (e.g., source of funds or explanation of purpose) before approval.
Records
Kin maintains complete and accurate records of:
- Member registrations and verification data;
- Mutual Aid Club purposes and responsible members (admins);
- All transactions conducted through the platform; and
- Any Anti Money Laundering (AML) investigations or Suspicious Activity Reports (SARs) made.
Records are retained for five years after a member’s account is closed or a Mutual Aid Club is terminated. All data is handled in accordance with Kin’s Data Protection Policy and UK GDPR.
Training
All relevant staff and board members will receive regular training on:
- Recognising suspicious activity;
- How to report concerns;
- The importance of confidentiality and lawful handling of information.
Training will be refreshed annually or when legislation or operational procedures change.
Risk Assessment
Kin Cooperative will regularly assess the money laundering and terrorist financing risks associated with its activities, members, and geographic operation. This risk assessment forms the basis for our controls, including the transaction limits and verification steps outlined in this policy.
Suspicious Activity Reporting (SAR)
Any staff member who suspects that funds may be linked to money laundering, fraud, or terrorist financing must report their concern immediately to the MLRO.
Reports should be made using Kin’s internal reporting form or via secure email to info@kin.coop
The MLRO is responsible for:
- Reviewing and evaluating all internal reports;
- Deciding whether a Suspicious Activity Report (SAR) should be filed with the National Crime Agency (NCA) via the online SAR portal;
- Recording all reports and decisions in a confidential SAR register; and
- Maintaining appropriate records for at least five years.
Under section 333A of the Proceeds of Crime Act 2002, it is an offence to inform a person that a SAR has been, or may be, submitted. Accordingly, no information relating to a report may be disclosed to the person or group under suspicion. The MLRO may restrict or delay transactions pending NCA guidance.
Terminology
MLRO - Money Laundering Reporting Officer
SAR - Suspicious Activity Report
NCA - National Crime Agency
AML - Anti Money Laundering
Effective Date: 06.11.25
Next Review: 06.11.26