Anti-Money Laundering Policy

BM Property Consultancy Ltd is committed to ensuring adequate controls and measures are in place to counter money laundering and terrorist financing activities, in accordance with the Money Laundering Regulations 2024.  We are registered and supervised by HM Revenue & Customs for compliance.

HOW WE MANAGE RISK

Risk Assessment

The Money Laundering Regulations require us to risk assess our business relationships to understand our customers and identify behaviour and circumstances that may indicate a higher risk of money laundering and terrorist financing activities. We have undertaken and documented a thorough risk assessment and subsequently implemented the appropriate policies and procedures required to minimise this risk.

Training

The company is committed to Continuing Professional Development (CPD) and staff training in anti-money laundering legislation to ensure they are aware of the risks of money laundering and terrorist financing, the relevant legislation, and their responsibilities under that legislation and that they are fully trained in the firm’s procedures in how to identify and deal with potential money laundering or terrorist financing activities.

Auditing

Internal compliance audits are carried out on a regular basis and all Customer Due Diligence (CDD) carried out is approved prior to the business relationship with the client or counterparty to the transaction commencing.  Any remedial action and/or further training required is identified and implemented in a timely fashion.

As a regulated business, we are subject to Anti-Money Laundering Regulations which means we must obtain and hold identification and proof of address for all customers. We are also required to establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place, hence, we would request you to identify anyone who you would consider to be a beneficial owner.  Where appropriate, the source or destination of funds may also be requested.  Without this information we will be unable to proceed with any work on your behalf. Below is a list of acceptable identity documents. We require sight of all original or certified documents. Subject to your individual circumstances, we may liaise with you for further/other documentation.

CUSTOMER DUE DILIGENCE (CDD) MEASURES

The Individual

Adherence to the approved Customer Due Diligence identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism. Proof of Ownership (where relevant) is also carried out electronically, as part of our standard CDD process.

It is a legal requirement that all vendors, landlords, purchasers, and tenants must be fully identified, and will be subject to an Anti-Money Laundering (AML) check. 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.

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.

There is a fee payable by the client for the AML check which is non-refundable.  Contact us for the current fee payable. 

If for any reason the verification of the customer’s identity is done by documents, then a list of acceptable documents is available.

Company or other legal structure

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 Enhanced Due Diligence (EDD) on those individuals identified. We will also obtain and hold on file official/company documents, as detailed below. 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) 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

Enhanced Due Diligence – High Risk Matters and Clients

We must carry out Enhanced Due Diligence in any case where there is a high risk of money laundering. The law says that includes the following.

  • We are dealing with a person established in a high-risk country: High-risk and other monitored jurisdictions
  • The client is a “politically exposed person” (known as a PEP), or a family member or known close associate of a PEP.
  • The client has provided false or stolen information.
  • A transaction is complex and unusually large.
  • There is an unusual pattern of transactions, and the transactions have no apparent economic or legal 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 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. Contact details for the appointed MLRO are provided below.

WARNING: Suspicious activity will be reported to The National Crime Agency (NCA)

RECORD KEEPING

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 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 had 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 and will not be used for any other purpose.

MONEY LAUNDERING REPORTING OFFICER: Barbara McLeish

Email: admin@bmpropertyconsultancy.uk