Agents Client Identification and Risk Assessment

Commercial Property Lettings Agency Client Identification and Risk Assessment Form

PROP.AML.CP.03

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.

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