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 addressand photo ID(e.g., passport, driving licence).
• Identify beneficial ownersif dealing with companies or trusts.
• Apply Enhanced Due Diligencefor high-risk clients (e.g., politically exposed persons).

5. Red Flags to Watch For

Staff must be alert to:

• 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 immediatelyto the MLRO.
• Do notinform the client (this is known as tipping off, which is a criminal offence).
• 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 yearsafter the end of the business relationship.
• Store securely and ensure accessibility for audits.

8. Training

All staff must complete AML training:

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

9. Penalties for Non-Compliance

Failure to comply can result in:

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