Commercial Property Lettings Agency Firm Wide Risk Assessment
This Template Commercial Property Lettings Agency Firm Wide Risk Assessment is for use by Commercial Property Letting Agents dealing with high value lettings (at a monthly rent of 10,000 euros or more) to assess the risks of money laundering and terrorism financing to which its business may be subject.
This template must be read in conjunction with our Commercial Property Lettings Agency Anti-Money Laundering Policy and Commercial Property Lettings 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’), letting agents dealing with high value lettings must have a risk assessment in place. The risk assessment must be in writing and subject to annual review. HM Revenue & Customs (the supervising authority for letting agents dealing with high value lets) can request a copy of this risk assessment which you must provide to them.
Letting agents who are caught by the Regulations 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.
Letting agents caught by the Regulations 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 letting 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.
Guidance from HM Revenue & Customs on the money laundering regulations can be accessed here. HM Revenue & Customs will produce specific guidance for letting agents on money laundering supervision but this has not yet been published after more than a year since the Regulations came into force.
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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