Aspire Estates AML Policy

Money Laundering Policy Statement

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Money laundering is the manipulation of illegally obtained funds by criminals and terrorists to give the appearance of them coming from a legitimate source and therefore disguising their origin. A risk sensitive or risk-based approach is where businesses assess the risk of customers laundering money through their business. Whilst Aspire Estates takes the starting point that most customers will not launder money we do identify criteria that may indicate a higher risk of money laundering – e.g. where there is no face-to-face meeting to establish identity.

It is the policy of Aspire Estates that all our customers provide identification.

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It is incumbent on letting agents to look out for suspicious activity and to have in place procedures to identify customers and to verify their legitimacy in order to prevent money laundering and terrorist financing. 

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Aspire Estates has a Money Laundering Reporting Officer (Owner, Hannah Roberts-Burt) whose responsibility is to forward reports to National Crime Agency (NCA) as necessary should any suspicious activity be suspected. Hannah is based at our Penzance office.

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Aspire Estates is committed to keeping up to date with anti-money laundering legislation.

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In the case of Landlords, proof of ownership of the property being let is also required (eg a mortgage statement, a copy of the title deeds or copy of the lease).

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In the case of tenants from abroad, if they require a visa to enter the country, we require a copy of that visa.

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For overseas vendors and landlords the same checks as for domestically based customers are applied. Additionally a Land Registry check can be made to determine proof of ownership. The risk is assessed and, if not satisfied, further checks into the identity of the individual may need to be obtained. 

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Where practically possible It is Aspire Estates policy that all Landlords & Tenants must be identified fully with a minimum of two forms of ID, evidence of identity being photographic and also evidence of residence e.g. a utility bill dated in the last three months. 

If the verification of the customer’s identity is done by documents this should be based on:

A government issued document with the customer’s full name and photo with either the customer’s date of birth or residential address such as:

• a valid passport

• a valid photo card driving license

• a national identity card

• a firearms certificate

• an identity card issued by the Electoral Office for Northern Ireland

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Where the customer doesn’t have one of the above documents, or the customer doesn’t meet the criteria in our risk assessment, we will require the following:

• a government issued document (without a photo) which includes the customer’s full name and also secondary evidence of the customer’s address, for example an old style driving license or recent evidence of entitlement to state or local authority funded benefit such as housing benefit, council tax benefit, pension, tax credit .

• secondary evidence of the customer’s address (not downloaded from the internet) for example a utility bill, bank, building society or credit union statement or a most recent mortgage statement

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For customers who are not private individuals, such as corporate customers and private companies, 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 – a search at Companies House will reveal details of directors and company secretary.

The above requirements for documentation will be applied to all shareholders holding 25% or more of a business.

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Suspicious Activity Reporting

A report should be made if the nominated officer thinks that there is a possibility, which is more than fanciful, that a person is or has been engaged in money laundering or terrorist financing, they will make a Suspicious Activity Report (SAR) to the National Crime Agency (NCA)

What is Suspicious Activity?

This list is by no means exhaustive but includes:

New Customers:

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

Regular/Existing Customers:

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

Record Keeping

The following records are required to be kept for 5 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.

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.