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.
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
List B – Proof of Address
List C – Proof of Ownership
List C – Probate
If you are acting as a representative of an estate, we require:
If you are acting as a representative of a UK Company, we will require:
If you are acting as a representative of an Offshore Company, we will require:
If you are acting as a Representative of a Trust we require:
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:
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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