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Commercial Property Estate Agency Firm Wide Risk Assessment


This Template Firm Wide Risk Assessment is for use by estate agents dealing with commercial property, to assess the risks of money laundering and terrorism financing to which its business may be subject.

This template should be read in conjunction with our Commercial Property Estate Agency Anti-Money Laundering Policy and Commercial Property Estate Agency Customer Identification and Risk Assessment Form.

Under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended by The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (‘the Regulations’), all regulated businesses must carry out a risk assessment. The risk assessment must be in writing and subject to annual review. HM Revenue & Customs (the supervising authority for estate agents) can request a copy of this risk assessment which you must provide to them.

Under the Regulations estate agents are required to gather information in order to prepare their risk assessment. For example, agents may review old files or discuss risks with staff or ask staff to complete a questionnaire. How and what information is gathered must be recorded and provided to HM Revenue & Customs upon request.

Estate agents must review all guidance and information provided by HM Revenue & Customs to assist with anti-money laundering. HM Revenue & Customs has produced a useful guide for estate agents to ensure they are compliant with the Regulations. The guidance can be found here.

Estate agents must consider the risk factors that their own business may be exposed to and identify these in their assessment. This Template has a list of risks which estate agents are likely to be exposed to. The list is not exhaustive.

Our anti-money laundering templates are an EXAMPLE ONLY and are intended to be a starting point for you to implement the requirements set out in the legislation and guidance.  You must tailor the templates to suit your own business. These templates must be read alongside the relevant money laundering regulations and specific HM Revenue and Customs guidance.

If you are unsure how to edit or adapt these templates in accordance with the relevant legislation and guidance, professional advice should be sought.  

Failure to comply with the 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 Regulations. 

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