Anti Money Laundering

EQUITY ESTATE AGENT’S POLICY STATEMENT

ANTI MONEY LAUNDERING REGULATIONS 2017

On 26th June 2017 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (more commonly referred to as The Money Laundering Regulations 2017) came in to force in the UK.

Under the Regulations it is an offence to trade as an Estate Agent unless registered with HMRC for anti-money laundering supervision.

Risk sensitive policies and procedures are 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 money through their business.

Businesses may take the starting point that most customers will not launder money but will identify criteria that would indicate a higher risk of money laundering – i.e. where there is no face to face meeting to establish identity.

Equity has appointed a money laundering officer, Panny Ellinas, whose responsibility it is to receive internal reports and to forward reports to the National Crime Agency as necessary.

Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risk of our business being used to launder money or fund terrorism. Although letting agents are not currently covered by the Regulations, we do request photographic identification and proof of address (utility bill from within last 3 months) from all landlords as well as vendors and buyers.

We will also at our discretion use the service of a third-party company to provide an online check. Should a face to face meeting not take place then enhanced due diligence procedures will be adopted by asking for additional information or evidence to establish the customer’s identity and ensuring that the documents supplied are certified.

We may also ensure that the first payment is made to a bank account in the customer’s name.

Acceptable Proof of Identity documents are listed below. You cannot use one form of identification for both name and address. For example, if you provide your driving licence as proof of your name you must provide another form of identification for your address, such as a passport. Equity require to see all original or certified documents in person.

Equity Estate Agents require one document from list A (Identity) and another document from list B (Proof of address).

A - IDENTITYB – PROOF OF ADDRESS
Current signed PassportValid UK/EU/EEA Driving License
Valid UK Driving LicenseBank Statements (last 3 months)
EEA Member State Identity CardCredit Card Statement (last 3 months)
Mortgage Statement (dated within last 12 months)
Utility Bill (dated within last 6 months)
Phone Bill (dated within last 6 months)
Council Tax (dated within last 12 months)
Tenancy Agreement (dated within last 12 months)
Benefit Entitlement Letter (dated within 12 months)
HMRC Tax Notification (dated within 6 months)
Home Insurance Certificate (dated within last 12 months)
Motor Insurance Certificate (dated within last 12 months)
Letter from Solicitor confirming house purchase
(dated within last 3 months)
NHS Medical Card (dated within last 3 months)
Electoral Register Entry (dated within last 12 months)

Probate

If you are acting as a Representative of an Estate, we require the following:

  • Grant of Probate (if a will was left)
  • Letter of administration (if no will left)
  • Individual identity evidence from List A & B for the Personal Representative, either executor or administrator

Limited company

If you are acting as a Representative of a UK Company, we will also require the following:

  • Certificate of Incorporation
  • Articles of Association
  • Memorandum of Association
  • Latest Annual Return or Confirmation Statement, with details of current company officers
  • If offshore, nominee director declaration and a general power of attorney
  • Individual identity evidence from List A & B for all individuals or entities with 25% or more of the shares or voting rights in the company

If you are acting as a Representative of an Offshore Company, we will also require the following:

  • Certificate of Incorporation
  • Articles of Association, Memorandum of Association, Latest Annual Return with details of current company officers, Share Certificate(s) showing the Ultimate Beneficial Owner OR
  • Certificate of Incumbency
  • If the shares are owned by another company, repeat steps above for the holding company
  • Nominee director declaration and/or general Power of Attorney (if applicable)
  • Individual identity evidence from List A & B for all individuals or entities with 25% or more of the shares or voting rights in the company

Trust

If you are acting as a Representative of a Trust, we require the following:

  • Trust deed
  • List of trustees
  • List of beneficiaries
  • Individual Identity evidence from List A & B for all individuals with a vest interest in 25% or more of the capital and/or those who exercise control over the Trust

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