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Commercial Property Lettings Agency Anti-Money Laundering Policy


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.

This template should be read in conjunction with the Commercial Property Lettings Agency Firm Wide Risk Assessment and Commercial Property Lettings Agency Customer Identification and Risk Assessment Form.

Under The Money Laundering and Terrorist Financing (Amendment) Regulations 2019 (‘the 2019 Regulations’), letting 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 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 2019 Regulations, letting agents dealing with high value residential 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 HM Revenue & Customs guidance and HM Revenue & Customs recommend this is done annually.

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. 

Guidance from HM Revenue & Customs on the Regulations can be accessed hereHMRC’s tailored guidance for letting agents can be accessed here.

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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