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Your anti money laundering checklist

Mark Hayward

Your anti money laundering checklist

With all the recent changes to money laundering legislation, we asked NAEA Propertymark’s Mark Hayward for a summary of the things you need to put in place. Here’s his 5 point checklist for keeping your business protected.

Is your business protected from money laundering?

Estate agencies are at high risk of being used by criminals for money laundering. You need to have measures in place to minimise the risk of this happening and make sure you’re compliant.

1. Register with HM Revenue and Customs for anti-money laundering supervision

It’s an offence to trade as an estate agent and you’ll have to pay a penalty if you’re found not to be registered. Make sure you renew in a timely manner, as this can now only be completed online.

2. Check that your buyers and sellers are who they say they are

You’ll need to obtain:
• Their name
• A photograph on an official document which confirms their identity
• Their residential address or date of birth.
This is usually covered by a passport or Driving Licence plus a current utility bill or bank statement.

3. Put in place internal controls and monitoring systems

It is a legal requirement that you have a Money Laundering Reporting Officer:
• Appoint a “nominated officer” for employees to report suspicious activity to
• Identify the responsibilities of senior managers and provide them with regular information on money laundering risks
• Train relevant employees regularly on their anti-money laundering responsibilities and keep
accurate records
• Document your anti-money laundering policies and procedures
• Check requirements, dependent on company size, to appoint a separate Compliance Officer.

4. Create a policy statement for your business

This should detail:
• Your anti-money laundering policy and procedures – including naming relevant individuals and their responsibilities
• Your procedures on a risk-based approach for identifying and verifying customers
• A summary of the monitoring controls that are in place
• Your commitment to training employees so they’re aware of their responsibilities and the need to promptly report suspicious activity to the nominated officer.

5. Keep records

You need to keep a record of all customer checks you carry out, including the relevant paperwork. It’s crucial to have this in writing if there’s an investigation into one of your customers. Records need to be kept for five years. If you have more than one office, annual audits of your additional branches will need to be carried out and recorded. You are required to carry out due diligence on all new staff and best practice suggests you carry this out on existing staff, too.

“Records” can include transactions, receipts, cheques and customer correspondence – either original copies, photocopies, scanned or electronic copies. Records must be kept for five years from the point that a business relationship ends or from the date a transaction is completed.

Mark also recently joined us for a live webinar where he covered money laundering legislation in more detail. To watch the full webinar replay, just click the link below.

Watch the webinar recording