This is the Money Laundering Policy for Chosen Home Limited.
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.
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 Rob Shotton. 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 customers date of birth are as follows:
Examples of acceptable residential address documents (without photo) are as follows:
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 (httpsssss://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:
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:
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:
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 17th August 2022 and the next review will be 17th August 2023.