This policy outlines how PropertyLoop complies with the Money Laundering Regulations 2017, Proceeds of Crime Act 2002, and guidance from HMRC and Propertymark (Apr 2024 edition).
1. Scope and Legal Responsibility:
- This policy applies to all properties let for £8,600 (10,000 EUR) per calendar month or more.
- Senior management are personally liable for breaches of AML compliance.
2. Registration:
- The agency is registered with HMRC for AML supervision.
- We notify HMRC of all relevant sales and letting activity in scope.
3. Risk Assessment:
- A written risk assessment is reviewed annually, assessing:
• Customer type (tenant or landlord)
• Geographic risk (high-risk jurisdictions)
• Payment method (bank transfer only)
• Property type or complexity
- High-risk cases are flagged for Enhanced Due Diligence (EDD).
4. Customer Due Diligence (CDD):
- For tenants and landlords: we verify full name, photo ID, proof of address, source of funds, and beneficial ownership where applicable.
- We obtain Companies House checks for company clients.
- No transaction proceeds unless doubts about identity are resolved.
5. Enhanced Due Diligence (EDD):
- Applied where:
• Customer is a Politically Exposed Person (PEP)
• Client is from a high-risk country
• Transactions are unusually complex or high value
- Requires senior management approval and ongoing monitoring.
6. Ongoing Monitoring:
- All tenancies and landlord relationships are monitored for unusual changes or behaviour.
- Risk scores and records are updated if new risks arise.
7. Suspicious Activity Reports (SARs):
- Staff report suspicions immediately to the MLRO.
- The MLRO reviews, investigates, and submits SARs to the NCA as required.
- Internal reporting is documented, and no tipping off is permitted.
- DAML requests are made where appropriate.
8. Money Laundering Reporting Officer (MLRO):
- The MLRO is [Insert Name & Role]
- A deputy MLRO is nominated in case of absence.
9. Record Keeping:
- All CDD, SARs, and internal reports are stored securely for 5 years after the relationship ends.
- Records may be hard copy or encrypted digital format, backed up off-site.
10. Staff Training:
- All relevant staff undergo AML training at induction and annually thereafter.
- Training outcomes and attendance are documented.
11. Controls and Audits:
- Random file audits are performed by the MLRO quarterly.
- Risk logs are updated monthly and available for HMRC inspection.
12. Breach Consequences:
- Breaches are reported to senior management and HMRC.
- Disciplinary action may be taken against employees who fail to comply.
This policy is reviewed annually and signed off by the Director.