Ethics, Governance & AML

Wesbridge Associates is dedicated to conducting business with integrity, transparency and in compliance with all applicable laws and professional regulations. We expect all staff, partners and stakeholders to uphold these values.

Wesbridge Associates is a small, supervised team. Roles and decision-making responsibilities are clearly allocated so that every client matter has a named adviser, a supervisor and a route of escalation.

• Nayab Sarosh Khalid — Director & Money Laundering Reporting Officer (MLRO). Statutory director of Wesbridge Associates Limited. Responsible for the firm's anti-money laundering regime, suspicious activity reporting and overall financial responsibility.
• Danish Farooq — Principal, Head of Practice & Authorised Adviser. Owner of the firm and IAA-authorised adviser. Holds ultimate professional responsibility for the quality of immigration advice and case supervision.
• Fahad Zohaib Asghar — Compliance Officer. Responsible for monitoring adherence to the IAA Code of Standards, internal policies, file reviews and CPD records.
• Ibrahim Habib Al-Ojali — Paralegal. Provides case-preparation and administrative support to advisers, working under the supervision of the Principal.

Day-to-day operational decisions are taken by the Principal. Strategic, financial and regulatory decisions are taken by the Director, with input from the Compliance Officer and MLRO where relevant.

Wesbridge Associates Limited is wholly owned by Danish Farooq, the firm's Principal. The firm is independent of any sponsor, employer or government body and provides advice solely in the interests of its clients.

We have reciprocal referral arrangements with several solicitors' firms across the city: we support them with immigration work where it falls outside their core practice, and they refer immigration matters to us. We also refer clients to those firms where a matter requires work outside our IAA-regulated scope (for example, contested litigation reserved to solicitors).

These arrangements do not involve payments that depend on the outcome of advice, and they do not affect the independence of the advice we give. Any actual or potential conflict of interest is identified at intake and managed in line with the IAA Code of Standards. Where a conflict cannot be managed, we decline or withdraw from the matter.

Overall responsibility for the firm's finances sits with the Director, Nayab Sarosh Khalid. This covers bookkeeping oversight, banking, fee handling, refunds, tax, and ensuring that the firm has the resources to meet its obligations to clients and regulators.

• Fees are quoted in writing and confirmed in the client care letter before work begins.
• Payments are received through regulated payment processors and recorded against the client matter.
• Refunds, where due, are issued back to the original payment method.
• Disbursements paid on a client's behalf (for example, Home Office fees) are reconciled to the client file.
• Records are retained for the period required by HMRC and the IAA.

Our external accountants, SK Tax Accountants, act as the firm's independent reviewer. They prepare and review our statutory accounts, advise on tax compliance and provide an external check on our financial records on an annual basis.

The Director conducts an internal financial review every quarter. The review covers income and expenditure, reconciliation of payments to client matters, refund activity, disbursements and any unusual transactions flagged by staff. Findings are recorded and any required corrective action is tracked through to completion.

Wesbridge Associates complies with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), the Proceeds of Crime Act 2002 and applicable HMRC and IAA guidance.

Our Money Laundering Reporting Officer (MLRO) is the Director, Nayab Sarosh Khalid. The MLRO is responsible for receiving internal reports of suspicious activity, deciding whether a Suspicious Activity Report (SAR) should be filed with the National Crime Agency, and maintaining the firm's AML records.

Our AML controls include:

• A documented, risk-based approach to client and matter risk assessment.
• Customer Due Diligence (CDD) on all clients, including identity and address verification before substantive work begins.
• Enhanced Due Diligence (EDD) where required, including for politically exposed persons (PEPs) and higher-risk jurisdictions.
• Ongoing monitoring of the client relationship and source-of-funds checks where appropriate.
• Internal escalation of suspicious activity to the MLRO, with no tipping-off of the subject of the report.
• Staff training on AML obligations, refreshed annually.
• Record retention for at least five years from the end of the business relationship or completion of the transaction, as required by MLR 2017.

Concerns about money laundering involving our firm can be raised confidentially with the MLRO via the contact routes below.

Our ethical principles include:

• Professional integrity — acting honestly and ethically in all dealings
• Client confidentiality — protecting sensitive client information
• Regulatory compliance — adhering to IAA standards and UK law
• Fair treatment — treating all with respect and dignity
• Conflicts of interest — avoiding situations that compromise independence
• Anti-discrimination — zero tolerance for discrimination or harassment

Whistleblowing is the disclosure of information about suspected wrongdoing or dangers at work. In the UK, whistleblowers are protected by the Public Interest Disclosure Act 1998 (PIDA).

Protected by law. UK law protects employees and workers who report wrongdoing from being dismissed or penalised.

You should report concerns about:

• Criminal activity or fraud
• Breach of legal obligations
• Miscarriage of justice
• Danger to health and safety
• Immigration advice by unregulated persons
• Discrimination or harassment

Confidentiality and protection

All reports are treated confidentially. We will not tolerate retaliation against anyone who reports concerns in good faith. You are protected under UK whistleblowing legislation.

Confidential email

Reports go to the Compliance Officer and Director: admin@wesbridgeassociates.co.uk.

Phone

Ask for the Compliance Officer or Director in confidence: 020 3753 5594.

Internal reporting channels

• Compliance Officer — Fahad Zohaib Asghar
• MLRO / Director — Nayab Sarosh Khalid
• Principal — Danish Farooq

External reporting

If you prefer to report externally or internal channels are inappropriate:

• Immigration Advice Authority (IAA) — email complaints@iaa.gov.uk, phone 0345 000 0046, visit website
• National Crime Agency — Suspicious Activity Reports — report a suspicious activity
• Protect (independent whistleblowing charity) — advice line 020 3117 2520, visit website