Procedures and Policies
Anti-Money Laundering (AML) Procedures and Policies
Effective Date: 26/07/2024
Approved by: Adelina Mincheva – Director
Reviewed on: 26/07/2024
This document outlines the Anti-Money Laundering (AML) procedures and policies of ADEL REAL ESTATE LTD in compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
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1. Purpose
The purpose of these procedures is to:
• Prevent money laundering and terrorist financing activities within the operations of ADEL REAL ESTATE LTD.
• Ensure compliance with UK AML regulations.
• Protect the integrity of our business by mitigating legal and reputational risks.
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2. Scope
These procedures apply to:
• All employees, contractors, and consultants involved in property sales, rentals, or lettings.
• All clients (buyers, sellers, landlords, and tenants).
• All transactions conducted through ADEL REAL ESTATE LTD.
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3. Responsibilities
1. Money Laundering Reporting Officer (MLRO):
o Appointed individual responsible for overseeing compliance with AML laws.
o Adelina Mincheva is the MLRO for ADEL REAL ESTATE LTD..
2. All Staff:
o Must be vigilant and report suspicious activities to the MLRO.
o Required to complete regular AML training.
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4. Customer Due Diligence (CDD)
ADEL REAL ESTATE LTD will conduct Customer Due Diligence (CDD) for all clients involved in property transactions.
4.1 Identification and Verification
• For Individuals:
o Valid photo ID (passport, driving license).
o Proof of address (utility bill, bank statement dated within the last 3 months).
• For Businesses:
o Company registration documents (e.g., Companies House).
o Identification of Ultimate Beneficial Owners (UBOs) holding 25% or more of the company.
4.2 Enhanced Due Diligence (EDD)
EDD will be conducted in high-risk situations, such as:
• Clients from high-risk jurisdictions.
• Politically Exposed Persons (PEPs).
• Complex transactions or unusually large cash payments.
4.3 Ongoing Monitoring
• Regularly review client activity and update records if necessary.
• Monitor transactions for inconsistencies or suspicious patterns.
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5. Source of Funds and Wealth Verification
Verify the origin of funds for property transactions:
• Obtain bank statements or documents showing the source of the funds.
• For gifted funds, verify the donor’s identity and source of wealth.
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6. Record-Keeping
• Retain records for a minimum of 5 years from the end of the business relationship or transaction.
• Records to include:
o Client identification documents.
o Transaction details.
o Suspicious Activity Reports (SARs) submitted to the National Crime Agency (NCA).
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7. Suspicious Activity Reporting (SARs)
1. Identifying Suspicious Activity:
o Examples include unexplained wealth, reluctance to provide documents, or unusual transaction patterns.
2. Reporting to the MLRO:
o All suspicions must be reported to the MLRO using the internal SAR form.
3. Filing SARs with the NCA:
o The MLRO will assess reports and, if warranted, file a SAR with the National Crime Agency.
o Transactions may not proceed during the moratorium period (7 working days after SAR submission).
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8. Training
• Mandatory AML training for all staff at least annually.
• Training topics include:
o Recognizing money laundering risks.
o Conducting CDD and EDD.
o Reporting suspicious activities.
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9. Risk Assessment
1. Business Risk Assessment:
o Assess risks associated with geographic regions, types of clients, and transaction values.
2. Client Risk Assessment:
o Categorize clients as low, medium, or high risk based on their profile and transaction type.
3. Mitigation Strategies:
o Implement additional checks for higher-risk clients or transactions.
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10. Policy Review
• This policy will be reviewed annually or whenever there are changes in relevant laws or regulations.
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11. Non-Compliance
Failure to comply with AML policies may result in disciplinary action, fines, or legal consequences for ADEL REAL ESTATE LTD.
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Signed by:
Adelina Mincheva
Director
26/07/2024
This document ensures compliance with UK AML regulations and protects ADEL REAL ESTATE LTD against money laundering risks.
