Anti-Money Laundering (AML)

Anti-Money Laundering (AML) Policy 

1. Purpose

To ensure compliance with the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002, and related legislation. Estate agents are legally obliged to help prevent money laundering and terrorist financing.

2. Scope

This policy applies to all staff involved in property sales, lettings (where applicable), client onboarding, and financial transactions.

3. Key Responsibilities

• Compliance Officer (MLRO): Catrin Tudor, Office Manager and Company Secretary oversees AML procedures and reports suspicious activity.
• All Staff: Must follow AML procedures, complete training, and report concerns.

4. Customer Due Diligence (CDD)

Before entering into a business relationship, staff must:

• Verify the identity of buyers and sellers (and landlords/tenants if letting services are covered).
• Obtain proof of address and photo ID (e.g., passport, driving licence).
• Identify beneficial owners if dealing with companies or trusts.
• Apply Enhanced Due Diligence for high-risk clients (e.g., politically exposed persons).

5. Red Flags to Watch For

• Reluctance to provide ID or proof of funds.
• Unusual payment methods (e.g., large cash deposits).
• Rapid resale or undervalued property.
• Third-party involvement without clear reason.
• Overseas buyers with complex ownership structures.

6. Suspicious Activity Reporting

• Concerns must be reported immediately to the MLRO.
• Do not inform the client (this is known as tipping off).
• The MLRO will assess and, if necessary, submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

7. Record Keeping

• Keep CDD records for at least 5 years after the end of the business relationship.
• Store securely and ensure accessibility for audits.

8. Training

• On induction.
• Annually thereafter.
• Training records must be maintained.

9. Penalties for Non-Compliance

• Criminal prosecution.
• Unlimited fines.
• Reputational damage to the firm.