This Commercial Property Lettings Agency Client Identification and Risk
Assessment Form is for use by a lettings agency dealing with high value
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, 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 the 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 Commercial Property
Lettings Agency Anti-Money Laundering Policy and Commercial Property
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 HMRC if you are a
regulated business to ensure that you are complying fully with the
legislation. This template Commercial Property 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 Commercial Property 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.