Money Laundering Policy
This is the Money Laundering Policy for Homemove Sales & Lettings Limited t/a Home Move Sales and Lettings.
The purpose of our relationship with our customers is to act as an Agent for the sale of property. As an Estate Agent we are obliged to register with HMRC and we have done so.
We are required to assess the risks that criminals may exploit our business for money laundering and terrorist financing.
We act as Agents only and the transaction proper is handled by the sellers/buyers legal representative, and their financial institution or bank. The National Crime Agency recognises their risk assessment as high, compared to Estate Agents at medium
Our fees in themselves are not considered ‘high value’ though the property transaction is
We are a full service Estate Agent dealing with domestic property only. We are not dealing with high volume investment transactions or properties of very high value.
We meet the vast majority of our customers face to face. We rarely work for transient individuals, international individuals or businesses.
In 2019 there were almost 1,000,000 property transactions and only 635 SAR’s (Suspicious Activity Reports) were made by Estate Agents – this equates to just 0.13% of all SAR’s in 2019.
The law requires us to check the identities of our customers, or the ‘beneficial owner’ of a property, for whom we are acting as Agent. Our Nominated Officer for managing this process is Mike Taylor. All of our employees are required to be familiar with this policy.
We are required to confirm our customers (both sellers & buyers) identity by seeing acceptable photographic and residential documents. All sellers and buyers will be subject to an electronic anti money laundering check. Should the check be unsuccessful we will then seek further identification through approved documentation. Should a face to face meeting not take place or the transaction be one that is identified as high risk by the company then the electronic check will be run through on “High Risk” which will check the client more thoroughly. Again, should this not be successful further identification will be sought through approved documentation.
Examples of acceptable photographic documents including the customer’s date of birth are as follows:
- Valid passport
- Valid photo card drivers’ licence
- National identity card
- Firearms certificate
Examples of acceptable residential address documents (without photo) are as follows:
- Utility bill (dated in the last 6 months)
- Old style drivers’ licence (or new style where not used as photographic ID)
- Bank statement (dated in the last 3 months)
- Mortgage Statement (dated in the last 12 months)
- Current Local Authority Tax Bill
Although we are vigilant, we are not experts in spotting forgeries, especially those purportedly issued in other countries, but all staff are required to review the “Guidance on examining identity documents” published on the .gov website (https://www.gov.uk/government/publications/recognising-fraudulent-identity-documents). If we have doubts about a customer’s identity, we may decline to deal with them until we are sure. Any concerns should be reported to the Nominated Officer.
We are obliged to check if our customers are Politically Exposed Persons (PEPs). Domestic or foreign PEPs are individuals who are or have been entrusted with prominent public functions, for example heads of state or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. A family member or close associate of any of the above. As we predominantly deal in domestic properties not of the highest value and there are very few such persons it is unlikely that we will ever interact. If we do, the Nominated Officer will decide a course of action.
Here are some of the factors that we consider in deciding whether to submit a suspicious activity report when dealing with new transactions:
- checking the seller or buyer’s identity is difficult
- The seller or buyer is reluctant to provide details of their identity or provides documents which may be fake
- The seller or buyer is trying to use intermediaries to protect their identity or hide their involvement
- We are asked to go through several legal entities in order to identify the beneficial owner or we are unable to identify whether there are any beneficial owners
- No apparent reason for using our business’s services – for example, another business is better placed to handle the transaction
- The lifestyle of the seller or buyer does not appear to be consistent with our knowledge of their income or income does not appear to be from a legitimate source
- The buyer or seller are keen to buy or sell quickly at an unusually low or high price for no legitimate reasons
- Part or full settlement in cash or foreign currency, with weak reasons
- The buyer or seller, or their associates are subject to adverse media attention, have been disqualified as directors or have convictions for dishonesty.
Regular and existing customers
These are some of the factors that we consider when deciding whether to submit a suspicious activity report in relation to regular and existing customers:
- The transaction is different from the normal business of the customer
- The size and frequency of the transaction is different from the customer’s normal pattern
- The pattern has changed since the business relationship was established
- There has been a significant or unexpected improvement in the customer’s financial position which the customer cannot give a proper explanation of where money came from or their source of wealth or funds.
These are some of the factors that we consider when deciding whether to submit a suspicious activity report in relation to the transactions carried out:
- A third party, apparently unconnected with the seller or buyer, bears the costs, or otherwise pays the transaction costs
- An unusually big cash or foreign currency transaction
- The buyer will not disclose the source of the funds or the seller the source of wealth where required
- Unusual involvement of third parties, or large payments from private funds, particularly where the buyer appears to have a low income
- Unusual source of funds
Any suspicious activity will be reported to the Nominated Officer
The personal data we are obliged to collect under these regulations ‘is necessary in order to exercise a public function that is in the public interest’ and keep it for a minimum of five years. This means that we cannot lawfully delete it, even if requested under GDPR legislation until that period has elapsed. During that time, we may not use the data for any other purpose.
All staff are obliged to read this document acknowledging that they have read and understood it. They are also required to take an online test to show that they understand their basic duties.
In the event of any suspicious activity, the Nominated Officer is to be informed and they will decide whether to discontinue dealing with the client or make a SAR (Suspicious Activity Report).
Identity details are recorded securely on our agency software programme and all original documents are shredded and disposed of. The data will be kept for a minimum of five years. We believe this policy and our record keeping makes us fully compliant with current legislation
This policy is dated 1st January 2022, the next review will be due by 31st December 2022.
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