Anti-Money Laundering (AML) Policy

1. Purpose

This Anti-Money Laundering (AML) Policy sets out the procedures adopted by Roworths Estate Agemts to prevent money laundering, terrorist financing and financial crime.

The policy is designed to ensure compliance with:

• Money Laundering Regulations 2017 (as amended)
• Proceeds of Crime Act 2002
• Terrorism Act 2000
• Sanctions and Anti-Money Laundering Act 2018
• Relevant HMRC guidance

All staff must comply with this policy.

2. Scope

This policy applies to:

• Directors
• Employees
• Contractors
• Temporary staff
• Anyone acting on behalf of the company

The policy applies to all residential property sales activities.

3. AML responsibilities

Director / MLRO

The Money Laundering Reporting Officer (MLRO) is responsible for:

• overseeing AML compliance;
• maintaining policies and procedures;
• receiving internal reports of suspicious activity;
• determining whether a Suspicious Activity Report (SAR) should be submitted;
• maintaining AML records;
• ensuring staff receive training.

Staff Responsibilities

All staff must:

• complete customer due diligence;
• identify suspicious activity;
• follow company procedures;
• maintain accurate records;
• report concerns immediately.

4. Risk-based approach

The company applies a risk-based approach to AML compliance.

Risks are assessed through:

• the Business-Wide Risk Assessment;
• individual Client Risk Assessments;
• transaction monitoring.

Clients are categorised as:

• Low Risk
• Medium Risk
• High Risk

The level of due diligence applied will reflect the assessed risk.

5. Customer due diligence (CDD)

CDD must be completed before establishing a business relationship where required.

The company will:

• verify identity;
• verify residential address;
• establish ownership where applicable;
• identify beneficial owners;
• understand the nature of the business relationship.

Acceptable evidence may include:

• Passport
• Driving Licence
• Proof of Address
• Electronic Verification Results

No instruction should proceed where required identification cannot be obtained.

6. Beneficial ownership

Where a client is:

• a company;
• a trust;
• a partnership; or
• represented by another individual,

the beneficial owners must be identified and verified.

The ownership structure must be understood before proceeding.

7. Politically Exposed Persons (PEPs)

All clients will be screened for Politically Exposed Person status where appropriate.

Where a client is identified as a PEP:

• additional scrutiny will be applied;
• senior management approval will be obtained;
• Enhanced Due Diligence may be required.

PEP status alone does not prevent the company from acting.

8. Financial sanctions screening

Clients must be screened against applicable sanctions lists.

• Where a potential sanctions match is identified:
• the matter must be escalated immediately;
• no further action should be taken until reviewed;
• legal or regulatory reporting requirements must be followed.

9. Enhanced Due Diligence (EDD)

Enhanced Due Diligence may be required where:

• the client presents a higher risk;
• overseas jurisdictions are involved;
• ownership structures are unusually complex;
• source of funds is unclear;
• a client is a PEP;
• suspicious circumstances are identified.

EDD may include:

• obtaining additional identification;
• obtaining source of wealth information;
• obtaining source of funds evidence;
• enhanced monitoring.

10. Source of funds

Where appropriate, the company will seek to understand the origin of funds involved in a transaction.

Evidence may include:

• bank statements;
• completion statements;
• inheritance documentation;
• investment records;
• mortgage information.

Additional information may be requested where risk factors are identified.

11. Ongoing monitoring

Client relationships and transactions will be monitored for unusual or suspicious activity.

Examples include:

• inconsistent information;
• reluctance to provide documents;
• unexplained urgency;
• unusual ownership arrangements;
• unexpected third-party involvement.

Where concerns arise, the matter must be escalated immediately.

12. Suspicious Activity Reporting

Any employee who suspects money laundering or terrorist financing must report the matter immediately to the MLRO.

Employees must not:

• investigate independently;
• alert the client;
• disclose that a report may be made.

The MLRO will determine whether a Suspicious Activity Report (SAR) should be submitted to the National Crime Agency.

13. Tipping off

Employees must not disclose:

• that a SAR has been submitted;
• that an investigation may be underway;
• that law enforcement has been contacted.

Breaching tipping-off provisions may constitute a criminal offence.

14. Record keeping

The company will retain records including:

• identification documents;
• verification results;
• risk assessments;
• source of funds evidence;
• sanctions screening records;
• training records.

Records will normally be retained in accordance with the company's Data Retention Policy and applicable AML legislation.

15. Staff training

All staff involved in regulated activities must receive AML training.

Training will cover:

• money laundering risks;
• customer due diligence;
• suspicious activity indicators;
• sanctions compliance;
• reporting procedures.

Training records will be maintained.

16. Compliance monitoring

The company will periodically review:

• client files;
• risk assessments;
• AML procedures;
• staff training records.

Findings will be documented and corrective action taken where necessary.

17. Breaches

Failure to comply with this policy may result in:

• disciplinary action;
• regulatory reporting;
• termination of employment or engagement.

Serious breaches may constitute criminal offences.

18. Policy review

This policy will be reviewed:

• annually;
• following legislative changes;
• following material business changes;
• following significant compliance incidents.