Anti-Money Laundering and Counter Terrorism Financing Policy (UK)
The Agency Real Estate England Ltd
Last Updated June 2023
Introduction
This Anti-Money Laundering and Counter Terrorism Financing (AML/CTF) Policy outlines the commitment of The Agency Real Estate England Ltd ("we," "us," or "our") to prevent money laundering and the financing of terrorism in accordance with applicable laws and regulations in the United Kingdom.
Policy Statement
We are committed to maintaining the highest standards of integrity and complying with all applicable AML/CTF laws and regulations. We have implemented policies, procedures, and internal controls to prevent the use of our real estate and other services for money laundering or terrorist financing activities.
Legal Framework
We comply with the following key legislative and regulatory frameworks in the UK:
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
- Proceeds of Crime Act 2002
- Terrorism Act 2000
- Criminal Finances Act 2017
Risk-Based Approach
We apply a risk-based approach to identify, assess, and manage the risk of money laundering and terrorist financing activities. This includes conducting due diligence on customers, employees, and third parties involved in real estate and related transactions.
Customer Due Diligence (CDD)
We conduct thorough customer due diligence on all clients and parties involved in real estate transactions. This includes:
- Verifying the identity of individuals and legal entities involved.
- Assessing the purpose and nature of the business relationship or transaction.
- Monitoring and ongoing scrutiny of customer transactions.
Enhanced Due Diligence (EDD)
In high-risk situations or with higher-risk clients, we apply enhanced due diligence measures. This may include:
- Obtaining additional information to better understand the customer and transaction.
- Conducting additional verification steps.
- Seeking approval from senior management for higher-risk transactions.
Record Keeping
We maintain records of customer due diligence, transaction information, and suspicious activity reports as required by law. These records are securely stored for the prescribed period as specified in applicable regulations.
Training and Awareness
We provide regular training and awareness programs to our employees to ensure they understand their obligations, recognise money laundering and terrorist financing red flags and know how to report suspicious activity.
Reporting Suspicious Activity
We have procedures in place to encourage employees to report any suspicions of money laundering or terrorist financing activities promptly. We comply with our legal obligations to report suspicious activity to the relevant authorities, such as the National Crime Agency (NCA).
Compliance and Internal Controls
We have appointed a designated Money Laundering Reporting Officer (MLRO[TJ2] ) who is responsible for overseeing our AML/CTF program and ensuring compliance with applicable laws and regulations. We regularly review and update our internal controls and procedures to adapt to changing regulatory requirements.
Non-Tolerance of Money Laundering and Terrorist Financing
We have a zero-tolerance policy towards money laundering and terrorist financing. We will fully cooperate with law enforcement agencies and regulatory authorities to combat these illegal activities.
Communication and Updating the Policy
We communicate this AML/CTF Policy to all relevant employees, stakeholders, and customers. We periodically review and update the policy to reflect changes in laws, regulations, and best practices.
Contact Information
If you have any questions, concerns, or need to report suspicious activity related to money laundering or terrorist financing, please contact our Money Laundering Reporting Officer (MLRO) at:
The Agency Real Estate England Ltd
5 Penta Court
Station Road
Borehamwood
Hertfordshire
WD6 1SL
Phone: +44 (0) 203 994 1590