Anti-Money Laundering Policy

This firm is required to comply fully with the Money Laundering Regulations 2017 (‘‘Regulations’’) (Amendment) 2019 and as such we are required by law to get satisfactory evidence of the identity of our clients and and/or any third parties involved in the transaction. This information must be provided at the time of forming a business relationship. If this information is not provided as agreed, your transaction may be delayed, or we may have to withdraw our services from the sale. For an individual person, we require to a current form of photographic identification such as a current passport or driving licence and a document that provides a satisfactory proof of address such as a bank statement or utility bill which is no more than 3 months old. Please note if a driving licence is provided as a form of identification it cannot be used as a proof of address. 

The requirements for corporate entities such as companies or partnerships are more complex and you will be required to provide documentation e.g. certificate of incorporation, articles of association etc that confirm whom the beneficial owner is of the firm or the person(s) with significant control over it. The beneficial owner of a company is someone who has more than 25% of the shares or voting rights in the company or any person who exercises control over the management of the company. In the case of Trusts this might include full details of the Settlor and or the Beneficiaries.
Original documentation will be the required for verification purposes. In addition, we also reserve the right to use the services of third parties including on-line credit check companies to carry out identity verification of any client. In all cases and in line with the ‘Regulations’, the firm will retain copies of your ID in either paper or electronic form up to a period of 5 years after the date we have ceased the business relationship.

In addition to verification of the client the firm may have to verify the source of any funds that are being used for the purchase.  Funds received on your behalf from a third party require the same levels of identification and verification checks as the client themselves. For example, proof of funds in the form of a bank statement might be requested. In addition to verification of the source of funds there are occasions when the firm must be satisfied as to the source of wealth of any client instructing us, and we may need to ask you for an explanation of that source. 

This firm has a professional and legal duty to keep your affairs confidential. However, it is important to note that should the firm form a suspicion that a client is in any way concerned with money laundering we are under a legal obligation as set out in the Proceeds of Crime Act 2002 to make a formal report to the National Crime Agency (NCA) who are responsible for collating all reports of potential money laundering. The firm is legally prohibited from notifying the client that a report has been made or the outcome of such a report.