This Lettings Agency Client Identification and Risk Assessment Form is for
use by a lettings agency dealing with high value residential lettings (at a
monthly rent of 10,000 euros or more) when checking the identity of a new
client for Anti-Money Laundering purposes from the 10 January 2020. This
form can also be used to verify the other contracting party and/or any
beneficial owners. A separate form should be completed for each individual.
Under The Money Laundering and Terrorist Financing (Amendment) Regulations
2019 (‘the 2019 Regulations’), from the 10 January 2020, letting agents
dealing with high value lettings are being brought into the scope of money
laundering regulations and will be regulated by HMRC. As a regulated
business, letting agents caught by the 2019 Regulations are required to
identify and verify their clients, other parties to the transaction and
beneficial owners.
This template should be read in conjunction with our Lettings Agency
Anti-Money Laundering Policy and Lettings Agency Firm Wide Risk Assessment.
The Form prompts the Agent to check the client’s documents to prove their
name and address. A list of acceptable documents appears in the form. The
Agent then assesses the level of risk and records this on the form.
This form is suitable for simple due diligence. Enhanced due diligence may
need to be undertaken for high risk individuals and transactions.
You must read the 2019 Regulations and guidance issued by HM Revenue and
Customs if you are a regulated business to ensure that you are complying
fully with the legislation. This template Lettings Agency Client
Identification and Risk Assessment Form is intended as a starting point to
assist you in implementing the requirements set out in the legislation and
guidance.
Guidance from HMRC on the money laundering regulations can be accessed
here. We expect HMRC will produce specific guidance for letting agents
on money laundering supervision in due course but at the time of writing this
has not yet been published.
Failure to comply with the 2019 Regulations can result in civil penalties
or criminal prosecution. Senior managers and nominated officers can also be
found personally liable for a breach of the 2019 Regulations.
If you are unsure how to edit or adapt this template in accordance with the
2019 Regulations and guidance, professional advice should be sought.
This Lettings Agency Client Identification and Risk Assessment Form is in
open format. Either enter the requisite details in the highlighted fields
or adjust the wording to suit your purposes.
Once you have purchased access to the appropriate document folder click on
the “Download Document” link below. You will be asked what you want to do
with the file. It is recommended that you save the document to a location
of your choice prior to viewing.