AML Policy

Base Collective Limited

1. Our commitment

Base Collective Limited, trading as Base Collective, is committed to preventing its services from being used for money laundering, terrorist financing, proliferation financing, sanctions evasion or other financial crime.

We apply customer checks and monitoring appropriate to our services and the risks involved, in accordance with applicable UK legislation and relevant guidance.

This policy explains what customers can expect when applying for and using our company formation, registered office and director service address services.

Company number: 16392079
Contact address: Suite 5, The Barns, Lane End Farm, Kelsall Road, Ashton Hayes, CH3 8BH
Email: [email protected]
Telephone: 01244 740 525

2. Responsibility

Anna Louise Threadgold, Director, is responsible for Base’s anti-money laundering compliance and acts as its nominated officer.

Base maintains an internal business risk assessment, policies, controls and procedures covering customer acceptance, verification, monitoring, record keeping and reporting concerns.

These are reviewed at least annually and sooner following relevant changes to our business, legislation or identified risks.

3. Customers we accept

Our initial customer scope covers UK companies and customers requesting UK company formations where:

• All directors and ultimate beneficial owners are resident in the UK.
• Ownership and control can be understood and verified.
• The business has a lawful purpose.
• We can complete the required checks and manage the risks involved.

Residence is separate from nationality. UK-resident applicants of any nationality may apply, subject to the same checks.

UK residence or incorporation does not remove the need to assess overseas connections or other risk factors.

We may decline applications outside our service scope or where we cannot adequately understand the customer, ownership or proposed activity.

4. Information we require

Before approving a customer, we require a completed customer information form and appropriate supporting evidence.

Depending on the customer and service, we may request:

• Full name, date of birth, residential address and identity evidence.
• Company name, number, registered address and actual operating location.
• Business activities, intended markets and reasons for purchasing the service.
• Details of directors, shareholders and ultimate beneficial owners.
• Ownership percentages, voting rights and other control arrangements.
• An ownership chart and supporting documents for corporate shareholders or other ownership arrangements.
• Information about relevant overseas connections.
• Details of the person placing the order and their authority to act.
• Payment information and explanations of third-party involvement.
• Further evidence where enhanced checks are necessary.

Providing information about the person placing the order alone may not satisfy the checks required for the company and its owners.

5. Identity verification

We use Didit to support identity verification and screening. Depending on the required checks, this may involve an identity document, a live facial check and comparison with the document photograph.

Document uploads are permitted through the verification process. We may request clearer images, further evidence or an alternative verification method where necessary.

We compare verification results with the customer information form and other evidence. We may use company registers and other reliable independent sources to support our checks.

An automated verification pass does not mean that Base has approved the customer. We review the information and make our own acceptance decision.

Companies House identity-verification requirements are addressed separately where applicable. An AML check is not automatically confirmation that those requirements have been met.

6. Ownership and representatives

We must understand who ultimately owns or controls the customer’s business.

We may trace ownership through corporate shareholders or other arrangements to identify the relevant individuals. We do not rely solely on the Companies House register where further evidence is needed.

Where someone acts on behalf of a customer, we check their identity, role and authority. An introduction from an accountant, agent or other professional does not replace our own checks.

You must not conceal beneficial owners, submit misleading ownership information or use an intermediary to avoid verification.

7. Screening and enhanced checks

We screen relevant customers, directors, beneficial owners and other parties as appropriate for sanctions, politically exposed person connections and relevant adverse information.

We assess potential matches using available identifying information. A name match or allegation is not, by itself, proof of wrongdoing.

Where required or justified by risk, we carry out enhanced due diligence. This may include:

• Further identity, ownership or business evidence.
• Information about the source of funds or source of wealth.
• Clarification of complex structures or unusual instructions.
• Additional approval and monitoring measures.

Being a politically exposed person, or having a relevant family or close-associate connection, does not automatically mean an application will be refused. We apply the relevant requirements and assess the circumstances.

We will not activate a service or proceed with an instruction while a material sanctions concern remains unresolved.

8. Payment and approval

Payment is taken in full upfront at checkout through Stripe. All orders remain subject to completion of our checks and written approval.

Payment, an order acknowledgement, completion of the information form or a Didit result does not activate the service.

Before approval, we review the customer’s identity, business purpose, ownership, screening results and any additional evidence required.

Only after written approval may the customer use the address within the permission granted or have us proceed with an agreed company formation.

If an application is not approved before activation, we will refund the payment in full without deducting payment-processing or verification fees, subject to any legal restriction on returning funds.

Further details are set out in our Terms and Conditions.

9. Ongoing monitoring and changes

For ongoing relationships, we monitor relevant information and review customer records according to risk.

This includes ongoing screening where appropriate, periodic reviews and further checks when circumstances change.

You must notify us promptly about relevant changes, including:

• Directors, shareholders, beneficial owners or control arrangements.
• Residential addresses or countries of residence.
• Business activities or actual operating location.
• Authorised contacts, intermediaries or mail instructions.
• Other circumstances affecting the information previously supplied.

We may request updated documents or explanations. Approval of an existing customer does not automatically cover a new company, individual or beneficial owner.

For a one-off service, our ongoing relationship normally ends when the agreed work is completed unless another service continues. Further instructions may require a fresh review.

10. Address and mail misuse

Permission to use our address applies only to approved companies and individuals.

Customers must not share or resell permission, add unapproved recipients or use the address to misrepresent their business’s location, staffing, scale or activities.

We maintain records of authorised users, check mail recipients and periodically review address use. We investigate unknown recipients, unauthorised registrations and other inconsistencies.

Our initial service covers official correspondence only. We do not provide parcel or package handling.

Mail handling and address use are also governed by our Terms and Conditions and Acceptable Use Policy.

11. Incomplete checks and service restrictions

We may request further information, pause an application, restrict an instruction or suspend or terminate a service where:

• Required checks cannot be completed or maintained.
• Material information is inaccurate, misleading or withheld.
• We cannot adequately establish ownership or authority.
• An instruction appears inconsistent with the known customer or agreed service.
• Continuing would breach a legal obligation or present a risk we cannot appropriately manage.

Where lawful and appropriate, we will explain the concern and allow an opportunity to resolve it.

Immediate action may be necessary for serious concerns or legal obligations. We may be restricted from explaining certain decisions.

Suspension, termination and refunds will be handled in accordance with our Terms and Conditions and applicable law.

12. Reporting and cooperation

We assess concerns and make reports or disclosures to the relevant authorities where required by law.

We cooperate with lawful requests from HMRC, Companies House, law enforcement and other competent authorities.

Legal restrictions may prevent us from informing a customer about a report, enquiry or the reasons for a particular action.

A request for additional evidence, delayed approval or refusal does not necessarily mean that wrongdoing has been identified.

13. Records and personal information

We retain appropriate records of customer information, verification, ownership checks, screening, risk assessments, decisions and relevant activity.

Customer due diligence and supporting records are normally retained for five years after the business relationship ends or the relevant occasional transaction is completed, subject to applicable legal requirements and exceptions.

We review records for secure deletion when retention is no longer required or justified. A refund or termination does not automatically require immediate deletion of legally required records.

Personal information collected for AML purposes is used to meet our legal obligations and prevent financial crime. Any other use must have an appropriate legal basis and comply with applicable restrictions.

Our Privacy Policy provides further information about processing, providers, security, retention and individual rights.

The retention of AML records is separate from the 30-day retention of original physical mail described in our Terms and Conditions.

14. Onboarding form links

Customers receive an emailed link to an onboarding form that saves progress and can be revisited.

Treat that link as confidential because it may provide access to information entered into the form. Share it only with people authorised to access that information.

Notify us promptly if you believe a link has been disclosed to the wrong person or accessed without permission.

Use the verification and document-submission methods we direct you to. Do not send sensitive identity or payment information through general enquiry forms.

15. Contact and complaints

For questions about verification requirements or this policy, contact:

[email protected]

Complaints are handled under our published Complaints Procedure. Making a complaint does not remove any checks we are legally required to complete.

16. Policy updates

We may update this policy to reflect changes in our services, legal obligations, providers or identified risks.

Material changes affecting existing service arrangements will be communicated in accordance with our Terms and Conditions and applicable law.