Anti-Money Laundering (AML) Policy

Our agency operates in accordance with the Money Laundering Regulations 2017, which are designed to prevent money laundering and the financing of terrorism. As part of our legal obligations, we must verify the identity and address of all customers, including sellers, buyers, landlords, and tenants. We are also required to identify any other beneficial owners involved in a transaction.

We apply a risk-based approach across our business to detect and prevent fraudulent or suspicious activity. Our assessment processes help us evaluate the potential risk of money laundering in each transaction.

How We Manage Risk

We invest significantly in staff training on Anti-Money Laundering regulations. AML training is part of our induction programme and is reviewed annually to ensure compliance with new or updated legislation.

We have appointed a Money Laundering Reporting Officer (MLRO) and a Deputy MLRO. The MLRO is responsible for assessing reports of suspicious behaviour or activity and, where necessary, submitting a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).
Our nominated officer is [enter name], [job title], and our deputy officer is [enter name].

Customer Identification Requirements

To reduce the risk of money laundering, we carry out Customer Due Diligence (CDD) on all landlords, tenants, buyers, and sellers. This includes obtaining:

• Photographic identification
• Proof of address
• Proof of ownership (for landlords and sellers)

We use an online verification system (CREADS). There is a £30 inc. VAT charge for buyers and sellers completing the ID process.

Original documents must be checked in person by a member of staff, who will take and retain a copy. If originals cannot be provided in person, certified copies from a solicitor or the Post Office are acceptable.

Verification checks must be completed for all parties with a beneficial interest in the transaction.
Where rent payments are involved, the receiving bank account must be in the customer’s own name.
Additional documentation may be requested depending on individual circumstances.

Accepted Identification Documents

List A – Proof of Identity

• Valid passport
• Valid UK/EU photocard driving licence
• Home Office residence permit
• HMRC tax notification
• State pension or benefits letter

List B – Proof of Address

(Must be recent and include full name and address)

• UK/EU driving licence (if not used for List A)
• Council tax bill
• Benefits entitlement letter
• Local authority rent card
• Tenancy agreement
• Bank statement
• Utility bill (issued within the last 3 months)
• Landline telephone bill
• Home or motor insurance certificate
• NHS medical card or GP registration letter
• Police registration certificate

List C – Proof of Ownership

• Most recent mortgage statement
• Home insurance certificate
• Solicitor’s letter confirming purchase/deeds/land registration

Probate

For representatives of an estate:

• Grant of Probate (if a will exists)
• Letter of Administration (if no will exists)
• Identity documents from Lists A & B for the executor/administrator

Limited Company Requirements

If acting for a UK company, we require:

• Certificate of Incorporation
• Articles and Memorandum of Association
• Latest Annual Return or Confirmation Statement
• Nominee director declaration (if applicable)
• Power of Attorney (if applicable)
• ID from Lists A & B for any individual/entity holding 25% or more shares or voting rights

Offshore Companies

Additional documents required:

• Share certificates showing the ultimate beneficial owner or Certificate of Incumbency
• Supporting documents for holding companies
• ID from Lists A & B for all individuals/entities with 25%+ ownership

Trusts

If acting for a trust, we require:

• Trust deed
• List of trustees
• List of beneficiaries
• ID from Lists A & B for anyone with a 25%+ beneficial interest or control

Suspicious Activity Reporting

If at any stage we have reasonable grounds to suspect money laundering or terrorist financing—whether based on information received or behaviour observed—we are legally obliged to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA).

Examples of suspicious activity may include, but are not limited to:

• Overseas buyers purchasing without viewing the property
• Transactions significantly below market value
• Refusal or reluctance to provide identification
• Delays in providing required documents
• Requests to hold or transfer cash
• Use of intermediaries to obscure identities
• Funds being transferred overseas to third parties
• Unexplained changes in parties to a transaction
• Sudden or unexplained improvements in financial circumstances
• Failure to show proof of funds

Politically Exposed Persons (PEP) & Adverse Media Checks

We screen customers against the HM Treasury sanctions list and conduct PEP and adverse media checks. Publicly available news sources may be reviewed to support this assessment. Only reputable and verifiable sources are used, and all findings are documented.

Record Retention

All customer records and supporting documents are reviewed regularly by our Data Controller.
To remain compliant with regulatory requirements, records will be retained for the current tax year plus five further years from the date of our most recent transaction with the customer.