QuoteNod Anti-Money Laundering Policy (v2026-09-22)

QuoteNod Ltd is a company registered in England and Wales, company number 17446525, registered office 124 City Road, London, EC1V 2NX. This policy sets out how we stop QuoteNod being used for money laundering, terrorist financing or to get round UK financial sanctions, and what we do if we suspect it is. It follows the structure of the Law Society's guidance on anti-money-laundering compliance for small firms, adapted from a law firm to a software platform.

1. What QuoteNod does, and does not do

QuoteNod is software for UK trade businesses: quotes, electronic signatures, invoices and payment requests. A trader who wants to be paid online connects an account of their own with Stripe or GoCardless, each authorised by the Financial Conduct Authority. The customer pays through that provider, into the trader's own account, and the provider pays the trader out to their bank.

QuoteNod never holds, receives, controls or moves customer or trader money. It has no client account, wallet or balance, handles no cash, and supports only payments in pounds sterling between UK accounts. QuoteNod's own fee on each online payment is taken by the trader's provider and paid to QuoteNod as QuoteNod's own income; it is not customer money.

2. The law we work within

Proceeds of Crime Act 2002. It is an offence to conceal, arrange or deal with criminal property, and to tip anybody off that a report has been made or an investigation is under way.

Terrorism Act 2000. Equivalent offences for terrorist property.

Money Laundering Regulations 2017 (as amended). Because QuoteNod holds no funds and provides no payment services itself, we do not consider it to carry on business as a relevant person under these Regulations. We follow their structure — risk assessment, due diligence, record keeping, training and internal controls — as good practice.

Financial sanctions. Under the Sanctions and Anti-Money Laundering Act 2018 it is an offence to make funds or economic resources available to a designated person. The UK Sanctions List published on GOV.UK is the single list of UK designations.

3. Who is responsible

A director of QuoteNod Ltd is responsible for this policy and for making sure it is followed, and acts as our Money Laundering Reporting Officer (MLRO): the person who receives reports of suspicion, decides whether to report to the National Crime Agency, makes any report and keeps the records. Anyone who works for QuoteNod must follow this policy and report any suspicion to the MLRO straight away, without discussing it with the trader or customer concerned. To contact the MLRO, write to contact@quotenod.co.uk marked For the attention of the MLRO.

4. Our assessment of the risk

We keep a written, company-wide assessment of the money-laundering, terrorist-financing and sanctions risks QuoteNod faces, reviewed at least once a year and whenever the service changes. We rate the overall risk as low to medium. It is low because QuoteNod never handles money and every payment runs between regulated UK accounts that have been checked by the banks and providers involved. The risks we watch for are a fake or impersonated trader account used to receive criminal money, a trader receiving money on somebody else's behalf, and quotes or invoices used to disguise where money came from.

5. Checking the traders we work with

A trader cannot take payment online through QuoteNod until their payment provider has verified them. Stripe and GoCardless each check the identity of the business and the people behind it, and that the bank account they are paid into is theirs, under their own anti-money-laundering obligations, before they will pay anybody out.

On top of that, QuoteNod records each trader's name, business, trading address and contact details, and the bank details they give for transfers, which they must confirm as their own. Where something about an account gives cause for concern — including any of the warning signs in section 6, a trader who is or is connected to a politically exposed person, or a link to a high-risk country — we look more closely, can ask for more information, and can stop the account taking payments while we do. A trader who will not provide what we reasonably ask for cannot take payments through QuoteNod.

6. Watching for warning signs

We watch for activity that does not fit what we know about a trader, including:

- a payment far larger than the trader's usual jobs, or out of line with their trade;
- bank details changed shortly before a large payment;
- several accounts sharing the same bank account, device, address or phone number;
- quotes with vague descriptions, round sums, no job address, or work that could not be real;
- a payment split into smaller ones, apparently to stay under limits;
- one payer paying many traders, or many payers paying one new trader, in a short time;
- a request to refund money to a different account, or an overpayment followed by a refund request;
- a name or address that matches an entry on the UK Sanctions List.

One sign on its own proves nothing. It is a reason to look more closely.

7. Reporting suspicion

Anyone at QuoteNod who knows or suspects money laundering, terrorist financing or a sanctions breach reports it to the MLRO at once. The MLRO considers it, records the decision and the reasons whatever the outcome, and where there are reasonable grounds makes a Suspicious Activity Report to the National Crime Agency, asking for a defence against money laundering where one is needed before we continue. We tell the trader's payment provider where our agreement with them requires it. Tipping off is a criminal offence: nobody at QuoteNod will tell a trader or customer that a report has been made or is being considered.

8. Sanctions

QuoteNod may not be used by, or to make funds available to, anybody designated under UK financial sanctions. A possible match is checked against the full details on the UK Sanctions List before it is treated as a true one. On a true match we stop the account taking payments at once and report it to the Office of Financial Sanctions Implementation as its rules require.

9. Records

Records of the checks made on a trader are kept for five years after our relationship with them ends, and records of payments for five years from the payment, and are then deleted unless the law requires them to be kept longer or they are needed for legal proceedings. Records of any report to the National Crime Agency are kept separately and seen only by the MLRO. How we handle personal data is set out in our Privacy Notice.

10. Training, staff and review

The MLRO is trained on appointment and at least every two years, and anybody who works for QuoteNod in a role that could help spot or prevent money laundering is trained before they start and at least every two years after; we keep a record of it. People are checked before they are given access to trader records. At least once a year this policy, our risk assessment and how well they have been followed are reviewed by someone independent of the day-to-day work, and what they find is acted on.

11. Changes

We review this policy at least once a year, and straight away if we change payment providers, offer a new way to pay, serve traders outside the UK, or if the law or our providers' requirements change. If QuoteNod were ever to hold, receive or move money itself, it would stop and take legal advice first, because that would need its own FCA authorisation and this policy would no longer be enough.

Questions about this policy: contact@quotenod.co.uk.