This Anti-Money Laundering Policy is designed for a lettings agency
business dealing with high value commercial property lettings (at a monthly
rent of 10,000 euros or more) to put in place a policy to make staff aware
of money laundering, prevent money laundering taking place and assist staff
if any money laundering activity is suspected.
Under The Money Laundering and Terrorist Financing (Amendment) Regulations
2019, from the 10 January 2020, lettings agents dealing with high value
lettings are being brought into the scope of money laundering regulations.
Money laundering is the process of moving illegally acquired cash through
financial systems so that it appears to come from a legitimate source.
Criminals will try to conceal the origin and true ownership of the proceeds
of their activities in order to turn the money from “dirty” to “clean”.
Commercial property letting agents are often the first port of call in a
property transaction and so they are best placed to identify and verify the
parties to a transaction and report any suspicious activity at the outset
of the transaction.
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’) ) from the 10 January 2020, letting agents dealing with high
value lettings must have a written anti-money laundering policy in place.
A copy of the anti-money laundering policy must be given to all staff.
Staff must also receive anti-money laundering training. The anti-money
laundering policy should supplement staff training. This policy should be
reviewed regularly to ensure that it complies with HMRC guidance and HMRC
recommend this is done annually.
You must read the Regulations and the HMRC guidance if you are a regulated
business to ensure that you are complying fully with the legislation. This
template Lettings Agency Anti-Money Laundering Policy is intended as a
starting point to assist you in implementing the requirements set out in
the Regulations and guidance. You will need to tailor our template policy
to suit your specific business and practice in accordance with the 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 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. If you are unsure
how to edit or adapt this template policy in accordance with the
Regulations and guidance, professional advice should be sought.
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