Bee City Living Limited is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering Regulations 2017. Risk assessments will be carried out within our policies and procedures to help prevent money laundering and terrorist financing.
As an Estate agent, we are required to comply with the HMRC Regulation on Money Laundering and are registered and supervised by HM Revenue & Customs for compliance.
As part of mitigating risk, Bee City Living recognises that it is essential for all staff to receive training in anti money laundering legislation and as such all staff are trained to understand the company’s responsibilities and how to identify risk. Each member of staff is also provided with a copy of this Money Laundering Policy as a reminder of their responsibilities and where/how to report suspicious circumstances.
The Money Laundering Regulations require us to risk assess our business relationships in order to understand our customers and identify behaviour and circumstances that may indicate a higher risk of money laundering and terrorist financing activities. Bee City Living has undertaken and documented a thorough risk assessment and we have subsequently implemented the appropriate policies and procedures required to minimise this risk.
Adherence to the “Customer Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism. We recognise that under the regulatory guidance we can do this by either taking paper documentation or running an appropriate electronic Anti Money Laundering checks.
Customer Due Diligence (“CDD”)
CDD is used as a Money Laundering risk assessment and should be done before buyers or tenants take a property. CDD procedures should be applied to beneficial owners involved in the counterparty and property sale and to all customers and stakeholders before proceeding. Although we accept that the majority of our customers will not launder money, we must identify criteria that would indicate a higher risk of money laundering. An example of this is where we do not meet the client face-to-face at any point during the transaction.
We are required to check that our clients are who they claim as well as checking their identity as well, where appropriate, the source of funds for property purchases or on any property where the rent is of 10,000 Euros (GDP equivalent) or more.
CDD procedures may not be sufficient for people who are Politically Exposed Persons “PEP”, their families, and high-risk cases, so Enhanced Due Diligence (EDD) procedures should be applied to style people and cases.
Where the electronic verification process is unsuccessful or inconclusive, we will collect documents, as stipulated within the current regulatory guidance.
Whom must we check, and when?
Sellers: We need to verify all sellers at the start of any matter, before accepting instructions to market their property. In probate cases we must verify the identity of all executors (if more than one). Proof of Ownership (where relevant) is also carried out electronically, as part of our standard CDD process.
Buyers: We are also required to verify all buyers at the start of the business relationship once an offer has been accepted by a Seller and before sending out the Memorandum of Sale. Proof of Ownership (where relevant) is also carried out electronically, as part of our standard CDD process.
Lettings: We are required to verify all tenants, which means requesting official proof of their name and addresses, verifying all details and information they provide. Only then do we proceed with the tenancy.
Landlords: We are required to verify all landlords and they are verified similarly to checks on the “beneficial owner(s)” of companies or other entities who instruct us and anyone who is acting on behalf of someone else. A beneficial owner is someone who owns 25% or more of the company. Proof of Ownership (where relevant) is also carried out electronically, as part of our standard CDD process.
The Importance of our thorough client(s) due diligence checks, our firm’s reputation is our greatest asset. Not only will this ensure compliance with the law, but will tend to deter undesirable client(s).
Verifying an individual’s identity
We must “identify” our clients (which simply means asking them their name and address) and also to “verify” that information (which means requiring them to prove it). We also must run similar checks on the “beneficial owners” of companies or other entities who instruct us and anyone who is acting on behalf of someone else.
The normal process for a UK vendor is :
- See an original official document containing a photograph (such as a passport or photocard driving licence)
- Check that the details, including the photograph match our client
- Note down the document number in the Property Questionnaire
- Run a Smartsearch identity check using the client’s name and address, including the document number in the search.
The normal process for a UK purchaser is:
- Once an offer has been accepted write to the purchaser to explain the AML regulations and request that we verify their identity or identities. The template “offer accepted letter” to the purchaser contains the necessary wording. Purchasers can do this in a number of ways (which is explained in the letter).
- Purchasers can either visit the office, bringing with them their official photograph ID and a member of staff will verify the information. Purchasers can provide us (by email or by post) a certified copy of their official photograph document. Documents can be certified by a solicitor or at the Post Office
- Once we have proof of the photo ID we must then run a Smartsearch identity check using the purchaser(s)’ name and address, including the document number in the search.
For non-UK residents we need to ask for a clean copy of a government issued document such as a passport or identity card, proof of address and we must check the legitimacy of these documents using Smartsearch.
For customers other than private individuals
For customers who are not private individuals, such as corporate customers and private companies, we will take all reasonable steps to identify the Ultimate Owner and all Beneficial Owner/s and carry out EDD those individuals identified, as described above. We will also obtain and hold on file official/company documents, as detailed below.
A Company (including a UK LLP) which is not listed on a regulated market such as the London Stock Exchange:
- Copy of the Certificate of Incorporation
- Copy of the most recent filed Audited Accounts
- Details of the current company officers (Directors, Company Secretary and Shareholders)
A Company (including a UK LLP) which is listed on a regulated market such as the London Stock Exchange:
- A copy of a dated page from the website of the relevant stock exchange or
- A photocopy of the listing in a reputable daily newspaper
- Trust deed
- List of trustees
- List of beneficiaries
EDD will be carried out on all individuals with a vested interest in 25% or more of the capital and/or those who exercise control over the trust, as described above.
- Grant of Probate (where a will was left)
- Letter of Administration (where no will has been left)
EDD will be carried out on the executor or administrator, as described above.
In accordance with current legislation records of all Customer Due Diligence will be retained for at least five years from the end of the business relationship or five years from the date the transaction was completed.
The purpose of keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.
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 we cannot lawfully delete it, even if requested under GDPR legislation until this period has lapsed.
In consideration of our carbon footprint, copies of all personal data and any documents procured for the purposes of identity verification will be stored electronically via a secure system and will not be used for any other purpose.
Suspicious activity reporting
The staff member dealing with the individual/transaction will notify the Money Laundering Reporting Officer (MLRO) or Deputy MLRO if they have reason to suspect that a person may be engaged in money laundering and/or terrorist financing.
The MLRO and/or Deputy MLRO will review the information to hand and make a final judgement as to whether or not to submit a Suspicious Activity Report (SAR) to the National Crime Agency. Any decision made to submit a SAR will be confidential and not shared with the subject or any member of staff.
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