Anti-Money Laundering & Counter-Fraud Policy

1. Purpose

This policy sets out the measures implemented by MedsHut Online Pharmacy to prevent money laundering, terrorist financing, fraud, and misuse of its services. The policy supports compliance with the Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and Stripe Healthcare Merchant requirements.

2. Scope

This policy applies to all employees, contractors, superintendent pharmacists, responsible pharmacists, independent pharmacist prescribers, and any third parties acting on behalf of MedsHut Online Pharmacy.

3. Regulatory Status

MedsHut Online Pharmacy is owned and operated by Nojen Clinical Ltd and is registered with the General Pharmaceutical Council (GPhC) as a UK distance-selling pharmacy. The pharmacy supplies Prescription-Only Medicines (POM) and Pharmacy (P) medicines in accordance with UK medicines legislation and GPhC standards.

4. AML Risk Assessment

MedsHut is assessed as a low-risk AML business due to its regulated healthcare model. The following factors contribute to this assessment:

• Regulated healthcare model under GPhC supervision
• Prescription-only supply process requiring clinical assessment
• Delayed payment capture until clinical approval is granted
• Requirement for verified patient identity
• Mandatory clinical consultation before prescribing
• Physical delivery of medicines to verified addresses

5. Customer Due Diligence (CDD)

All patients must provide the following information before any medicines can be supplied:

• Full name
• Date of birth
• Residential address
• Relevant medical history

6. Transaction Monitoring and Controls

We implement robust transaction monitoring to detect and prevent fraudulent activity:

Payment Processing

• Payments are authorised at checkout but are not captured until a clinical decision has been made and a prescription has been approved
• This delayed capture model ensures no payment is taken for orders that are not clinically approved

Fraud Monitoring

Transactions are monitored for unusual activity including:

• Multiple cards associated with a single account
• Excessive refund requests
• Mismatched billing and delivery details
• Repeated failed payment attempts
• Unusual ordering patterns or quantities

7. Prescriber Oversight and Safeguards

All prescriptions are issued by GPhC-registered independent pharmacist prescribers who operate under strict clinical governance:

Prescriber Verification

Prescribers are verified prior to engagement and must provide:

• Evidence of GPhC registration
• Enhanced DBS clearance
• Right to work documentation
• Documented scope of practice

Clinical Governance

• Prescribing activity is subject to regular audit
• Clinical governance oversight is maintained by the Superintendent Pharmacist
• All clinical decisions are documented and traceable
• Prescribers must adhere to approved clinical protocols

8. Reporting Suspicious Activity

All staff are trained to recognise and report suspicious activity. Any concerns regarding potential money laundering, fraud, or unusual transactions must be reported immediately to the designated Money Laundering Reporting Officer (MLRO).

We cooperate fully with law enforcement and regulatory authorities in relation to any investigations concerning financial crime.

9. Record Keeping

Records of customer due diligence, transactions, and any suspicious activity reports are maintained for a minimum of five years in accordance with legal requirements. These records are stored securely and are available for inspection by regulatory authorities upon request.

10. Policy Review

This policy is reviewed annually or whenever there are significant changes to regulations, business operations, or identified risks. All staff receive training on AML and counter-fraud procedures as part of their induction and ongoing professional development.

11. Contact Information

For questions about this policy, please contact us: