Money Laundering Policy

Property Delight is registered with HMRC for anti-money laundering supervision under the Money Laundering Scheme.

 

Money laundering is the manipulation of illegally obtained funds by criminals and terrorists to give the appearance of them coming from a legitimate source and therefore disguising the funds origin.

Property Delight is committed to ensuring that adequate controls are in place to counter money laundering and terrorist financing activities in line with legislation, paying particular attention to The Money Laundering Regulation 2017, Proceeds of Crime Act 2002 and Terrorism Act 2000.

Risk

We are aware that the real estate industry is a target for organized criminals seeking to launder the proceeds of criminal activity, therefore risk sensitive policies and procedures must be established in order to anticipate and prevent money laundering and terrorist financing.

A risk sensitive or risk-based approach is where businesses assess the risk of customers laundering who may possibly launder money through their business. Businesses may take the start point that most customers will not launder money but will identify criteria that would indicate a higher risk of money laundering - e.g. where there is no face-to-face meeting to establish identity.

How we manage the risk

Property Delight is committed to staff training in anti-money laundering legislation.

We have Money Laundering Reporting Officer (MLRO) whose responsibility is to receive internal reports. Our MLRO seeks to prevent criminal activity by cooperating fully with the appropriate authorities and reporting suspicious activity to the National Crime Agency, as necessary.

Identification procedures

Adherence to the due diligence identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism.

All vendors, landlords, purchasers, and tenants must be fully identified, additionally we may need to collect information on and identify other individuals who have an interest in the property who are not considered to be our customers such as anyone who is gifting money towards as deposit.

On receipt of an acceptable offer for a property, we will request and assess sources of funds and sources of any cash element of the purchase price. Without adequate information we shall not proceed with marketing a property For Sale.

Rather than traditional methods in which you would have to produce multiple utility bills and a photographic ID, we use an electronic verification system. This system allows us to verify customers from basic details using electronic data, however it is not a credit check of any kind so will have no effect on you or your credit history. To do so, the Credit Referencing Agencies may check the details supplied against any particulars on any database (public or otherwise) to which they have access. They may also use the details in the future to assist other companies for verification purposes. A record of the search will be retained. In certain circumstances additional information may be required.

If for any reason the verification of the customer's identity is done by documents, then a list of acceptable documents is available such as: a valid passport, a valid photo card driving license, a national identity card, a firearms certificate, an identity card issued by the Electoral Office for Northern Ireland.

For customers other than private individuals

For customers who are not private individuals, such as incorporated entities, trusts and charities, the business must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company. We are required to obtain personal information for the beneficiaries of the entity and those in a position of control.

Suspicious activity reporting

A report will be made if a member of staff/the nominated officer thinks that there is a possibility that a person is or has been engaged in money laundering or terrorist financing.

The report will be made to the appropriate Money Laundering Reporting Officer who, should they be satisfied that there are grounds to suspect money laundering or terrorism, must forward a report to the National Crime Agency.

What is suspicious activity?

This list is by no means exhaustive.

New customers:

Reluctance to provide details of their identity

Customer is trying to use intermediaries to hide their identity or involvement

There appears to be no genuine reason for the customer using the business's services

Regular/existing customers:

 Money is paid by a third party who does not appear to be connected with the customer

The customer requests payment to a third party who has no apparent connection with the customer

A cash transaction is unusually large and the customer will not disclose the source of funds.

A transaction is carried out for less than market value with an unconnected person

Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential.

Record keeping

The following records are required to be kept for five years:

Copies of, or references to, the evidence obtained of a customer's identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed; and

Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed.

The purpose for keeping these records is to demonstrate the business's compliance with the regulations and to aid any resulting investigations.