Money Laundering Policy
The Robinson Jackson Group is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with legislation, paying particular attention to the Money Laundering Regulations 2017, Proceeds of Crime Act 2002 and Terrorism Act 2000.
This means we have to undertake due diligence processes to obtain identification and proof of address for all customers. Additionally, we are also required to establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place, therefore, we would request thet you identify anyone who you would consider to be a beneficial owner. Where appropriate, the source of wealth, source of funds, or destination of funds may also be requested. Without this information we will be unable to proceed with marketing a property For Sale or To Let or concluding an agreed purchase or tenancy.
We are aware that the real estate industry is a target for organised criminals seeking to launder the proceeds of criminal activity, therefore risk sensitive policies and procedures must be established in order to anticipate and prevent money laundering and terrorist financing.
A risk sensitive or risk-based approach is where businesses assess the risk of customers laundering who may possibly launder money through their business. Businesses may take the start point that most customers will not launder money but will identify criteria that would indicate a higher risk of money laundering - e.g. where there is no face-to-face meeting to establish identity.
How we manage the risk
The Robinson Jackson Group is committed to staff training in anti-money laundering legislation.
We have Money Laundering Reporting Officers (MLROs) whose responsibility is to receive internal reports. Our MLROs seek to prevent criminal activity by cooperating fully with the appropriate authorities and reporting suspicious activity to the National Crime Agency, as necessary.
Adherence to the due diligence identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism.
All vendors, landlords, purchasers, and tenants must be fully identified, 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.
If for any reason the verification of the customer's identity is done by documents, then a list of acceptable documents is available.
For customers other than private individuals
For customers who are not private individuals, such as incorporated entities, trusts and charities, the business must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company. We are required to obtain personal information for the beneficiaries of the entity and those in a position of control.
Suspicious activity reporting
A report will be made if a member of staff/the nominated officer thinks that there is a possibility that a person is or has been engaged in money laundering or terrorist financing.
The report will be made to the appropriate Money Laundering Reporting Officer who, should they be satisfied that there are grounds to suspect money laundering or terrorism, must forward a report to the National Crime Agency.
What is suspicious activity?
This list is by no means exhaustive.
- Reluctance to provide details of their identity
- Customer is trying to use intermediaries to hide their identity or involvement
- There appears to be no genuine reason for the customer using the business's services
- Money is paid by a third party who does not appear to be connected with the customer
- The customer requests payment to a third party who has no apparent connection with the customer
- A cash transaction is unusually large and the customer will not disclose the source of funds.
- A transaction is carried out for less than market value with an unconnected person
- Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential.
The following records are required to be kept for five years:
Copies of, or references to, the evidence obtained of a customer's identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed; and
Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed.
The purpose for keeping these records is to demonstrate the business's compliance with the regulations and to aid any resulting investigations.