Anti Money Laundering

DAVENPORT PROPERTY MANAGEMENT LIMITED

 

t/a HIGHFIELDS LETTING AGENTS

 

ANTI MONEY LAUNDERING POLICY STATEMENT

 

Highfields Letting Agents are committed to ensuring that there are adequate controls and measures in place to counter money laundering and terrorist financing activities, in accordance with the Money Laundering Regulations 2017.  We are registered and compliant with HM Revenue & Customs.

 

RISK ASSESSMENT

 

Due to the nature of the Letting Agency Market in which we operate, we assess our risk or susceptibility to money laundering as low on all matters.  Under the Money laundering & Terrorist Financing Regulations 2019, Highfields Letting Agency, does not meet the definition of a letting agency activity having dealings with a rent threshold of £10,000 per property, per month.  Therefore, our risk factor is low, however we maintain and carry out the policies and procedures as stated.

 

COMPLIANCE

 

We must meet certain day-to-day responsibilities as a Letting Agent which includes carrying out ‘customer due diligence’ measures to check that our clients are who they say they are.

 

We carry out Customer Due Diligence (CDD) checks on all new tenants and landlords prior to the commencement of the business relationship with the tenant or landlord.

 

For customers that are not private individuals, such as corporate customers and private companies; we take all reasonable steps to identify the ultimate owner and all beneficial owners and will carry out enhanced due diligence and hold on file all company documents received.

 

Below is a list of acceptable identification documents.  We would require sight of all the original documents. 

 

Individual Identification Documents
We require one document from List A and one document from List B

 

LIST A – Proof of Identity

 

·         Current signed Passport

 

·         Valid UK Driving Licence – Photo only, Full or Provisional accepted.

 

·         EEA member state identity card

 

LIST B – Proof of Address

 

·         UK/EU/EEU Drivers licence – if licence not used as proof of identity – Must be valid and photo only.

 

·         Bank or Building Society Statement – Dated within the last 3 months; this must include account name, number and show recent transactions.  Not general correspondence.

 

·         Credit Card Statement – Dated within last 3 months; this must include name and account number and show recent transactions. Not general correspondence.

 

·         UK/EU/EEU Mortgage Statement – Dated within 12 months; this must show account number. Not general correspondence.

 

·         Utility Bill – Dated within last 6 month, e.g., Gas, Electric or Water.  Must show address for service and account number. Not general correspondence.

 

·         Telephone Bill – Dated within 6 months – either landline or mobile phone, excluding pay as you go. Must show address and account number. Not general correspondence.

 

·         Council Tax – Dated within 12 months, this must show address and account number.  Not general correspondence.

 

·         Tenancy Agreement – Must be dated within 12 months; this must show full name and address.  This must be from local authority, solicitor or letting agent.

 

·         Benefit Entitlement Letter – This must be within 12 months and must be issued by the DWP or jobcentre plus.  This must confirm the type of benefit payable i.e., disability, housing etc.

 

·         HMRC Tax Notification – Must be dated within 6 months and must state national insurance number and tax calculation. No general correspondence.

 

·         Home or Car Insurance Certificate - Must be dated within 12 months and must state name, address and policy number.  No general correspondence.

 

·         Solicitors Letter confirming house purchase – Must be from a UK solicitor and must state full name and address of purchaser.

 

·         NHS Medical Card – Must be dated within 3 months.  Must state NHS number and date of birth.  No general correspondence.

 

Limited Companies

 

If you act on behalf of A UK Company, we would require:

 

·         Certificate of Incorporation or

 

·         Copy of filed audited accounts or

 

·         Details of company officers – i.e., Directors, company secretary and shareholders.

 

·         Identity evidence from List A&B for the individual dealing with the rental and all individuals or entities with 25% or more of the shares or voting rights in the company.

 

Probate

 

If you are acting as a representative of an estate, we would require: -

 

·         Grant of probate for when there is a will.

 

·         Letter of administration for when there is no will.

 

·         Identification for the individual from List A&B.

 

Companies (inc UK LLP) which is not listed on a regulated market such as the London Stock Exchange, we would require.

 

·         Copy of the certificate of incorporation

 

·         Copy of the most recently filed audited accounts.

 

·         Details of the current directors, company secretary and shareholders.

 

Companies inc UK LLP which is listed on a regulated market such as the London Stock Exchange, we would require: -

 

·         Copy of a page with the date of the relevant stock exchange or

 

·         A photocopy of the listing from a reputable daily newspaper.

 

 Enhanced Due Diligence

 

In some situations, we must carry out Enhanced Due Diligence. These situations are:

 

·         when the customer is not physically present when you carry out identification checks

 

·         when you enter into a business relationship with a ‘politically exposed person’ - typically, a non-UK or domestic member of parliament, head of state or government, or government minister and their family members and known close associates.

 

·         when you enter into a transaction with a person from a high risk third country identified by the EU

 

·         any other situation where there’s a higher risk of money laundering.

 

The enhanced due diligence measures for customers who are not physically present and other higher risk situations include:

 

·         obtaining further information to establish the customer’s identity.

 

·         applying extra measures to check documents supplied by a credit or financial institution.

 

·         making sure that the first payment is made from an account that was opened with a credit institution in the customer’s name.

 

·         finding out where funds have come from and what the purpose of the transaction is.

 

The enhanced due diligence measures when we deal with a politically exposed person are:

 

·         making sure that only senior management gives approval for a new business relationship.

 

·         taking adequate measures to establish where the person’s wealth and the funds involved in the business relationship come from

 

·         carrying out stricter ongoing monitoring of the business relationship

 

 

 

Control and Monitoring

 

We make sure that our business has adequate internal controls and monitoring systems which would alert us and other relevant people in the company if criminals try to use your business for money laundering. Once we are aware of a potential threat, we will take steps to prevent it and report any suspicious activity.

 

Our controls include:

 

·         appointing a ‘nominated officer’ and making sure that employees know to report any suspicious activity to them

 

·         training relevant employees on their anti-money laundering responsibilities

 

·         documenting and updating anti-money laundering policies, controls and procedures

 

·         introducing measures to make sure that the risk of money laundering is taken into account in the day-to-day running of our business.

 

 

 

Money Laundering Reporting Officer: -

 

Mrs Karen Davenport

 

Email: info@highfieldsestateagents.co.uk

 

 

 

Suspicious Activity reporting

 

The member of staff must report any suspicious transaction or activity they become aware of to the Money Laundering Reporting Officer (MLRO. It’s the Money Laundering Reporting Officers responsibility to decide whether they need to send a report or ‘disclosure’ about the incident to the NCA. They do this by making a Suspicious Activity Report (SAR) to the National Crime Agency.  Any decision that is made to submit a SAR is confidential and not shared with any member of staff.  Contact details for the MLRO are detailed above.

 

Record keeping

 

We keep a record of all customer due diligence in accordance with current legislation.  By keeping these records, we show that our business is complying with the Money Laundering Regulations. This is crucial to protect our business if there’s an investigation into one of our customers.  All records will be kept for at least 5 years from the end of the business relationship or the date the transaction has been completed.

 

The personal data we are required to collect under these regulations is necessary in order to  exercise a public function that is in the public interest, and we cannot lawfully delete it, even if there is a request under the GDPR legislation.  This can only be deleted once the period has lapsed.  All personal data and documents held for identification purposes, will be held electronically and not used for any other purpose.