Anti Money Laundering Policy

We are subject to the Money Laundering Regulations 2017 which aim to counter money laundering and the financing of terrorism. We have a legal duty to obtain identification and proof of identification and address from all our customers. We’re also obliged to ascertain whether other beneficial owners are involved on whose behalf the transaction or activity is taking place. We have adopted a risk sensitive approach throughout our business to recognise and prevent fraudulent transactions. We use a criteria-based system in order to assess the risk of money laundering.

HOW WE MANAGE THE RISK

We train our staff on Anti Money Laundering Legislation which is reviewed on an as necessary basis to ensure that any potential new or amended legislation is adhered to. It is the responsibility of our Money Laundering Reporting Officer (MLRO) to receive and action reports of suspicious behavior and activity and to complete and submit a “Suspicious Activity Report” (SAR) to the National Crime Agency when necessary.

IDENTIFICATION PROCESS

In order to alleviate the risk of attempted money laundering through our company, we carry out “Customer Due Diligence” (CDD) in regards to identification by requiring photographic ID and proof of address. For Sellers, we also require proof of ownership. All document copies must be certified by a notary, solicitor or at the post office. Verification checks must be completed on all individuals who have a vested interest in the transaction. For processing rent payments, we require the bank account to be in the customer’s name. Subject to your individual circumstances, we may liaise with you for further/other documentation.

INDIVIDUAL IDENTITY DOCUMENTS

We require one document from List A and one from List B from all customers” Where applicable, please ensure that documents include full name(s), service addresses and account numbers and are not provided in the form of general correspondence.

List A – Identity Document

  • Current signed Passport
  • Current UK/EU photo Driving License
  • Resident Permit issued to EU nationals by the Home Office
  • Inland Revenue Tax notification
  • State Pension or Benefits book/notification letter

List B – Proof of Address

  • Current UK/EU photo Driving License, if not used in A
  • Council tax bill
  • Benefits entitlement letter
  • Local authority rent card
  • Tenancy agreement
  • Bank statement
  • Utility bill from the last three months
  • Telephone bill excluding mobile pay as you
  • Home or motor insurance certificate
  • NHS medical card or letter from GP confirming registration
  • Police registration certificate

List C – Proof of Ownership

  • Most recent mortgage statement
  • Home or motor insurance certificate
  • Solicitors letter confirming house purchase/deeds/land registration

List C – Probate

If you are acting as a representative of an estate, we require:

  • Grant of Probate (if a will was left)
  • Letter of Administration (if no will left)
  • Individual identity evidence from List A & B for the personal representative, either executor or administrator

Limited Company

If you are acting as a representative of a UK Company, we will require:

  • Certificate of Incorporation
  • Articles of Association
  • Memorandum of Association
  • Latest Annual Return or Confirmation Statement, with details of current officers
  • If offshore, nominee director declaration and a general Power of Attorney
  • Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares/ or voting rights

Offshore Company

If you are acting as a representative of an Offshore Company, we will require:

  • Certificate of Incorporation
  • Articles of Association, Memorandum of Association, Latest Annual Return with details of current company officers, Share Certificate(s) showing the Ultimate Beneficial Owner OR
  • Certificate of Incumbency
  • If the shares are owned by another company, repeat steps above for the holding company
  • Nominee director declaration and/or general Power of Attorney (if applicable)
  • Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares/ or voting rights

Trusts

If you are acting as a Representative of a Trust we require:

  • Trust deed
  • List of trustees
  • List of beneficiaries
  • Individual identity evidence from List A & B for all individuals with a vest interest in 25% or more of the capital and/or those who exercise control over the trust

SUSPICIOUS ACTIVITY REPORTING

At any given stage of a transaction, should we feel there are reasonable grounds on which to suspect that money laundering or terrorist financing is taking place, whether it be in relation to information received or any other aspect of the sale or let, we are legally obliged to report and submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) at nationalcrimeagency.gov.uk.

Suspicious activity may include:

  • A transaction or valuation request for a property that is well below the market value (Our pre-fee financial model is based on RICS valuations only)
  • Reluctance to provide information to confirm one’s identity
  • Delaying the signing of contracts or providing copies of ID
  • Requesting that we hold cash in the client deposit account
  • Settlements being offered in cash
  • Intermediaries used to hide the identification of the buyer
  • Funds being sent overseas to a third party
  • No apparent reason for using our agency
  • Late changes to the parties involved in a sale/purchase
  • Significant improvement in one’s financial position
  • A reluctance to demonstrate source of funds

RECORDS RETENTION

In relation to record keeping and the data stored for all customers, this will be reviewed regularly by our data controller who will determine whether there is a continued requirement for the business to hold such information. To work in compliance with the regulations, we shall keep records and supporting records on file for the current tax year plus five years following the date of the most recent transaction with our company.

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