This Estate Agency Client Identification and Risk Assessment Form is for use by an Estate
Agent when checking the identity of a new client for Anti-Money Laundering
purposes. 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.
Estate agents are regulated by HMRC. A regulated business must comply with 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'). Under the Regulations estate agents 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 Estate Agency Anti-Money Laundering Policy and Estate 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 Regulations and guidance issued by HM Revenue and Customs if you are a regulated business to ensure that you are complying fully with the legislation. This template Estate Agency Client Identification and Risk Assessment Form is intended as a starting point to assist you in implementing the requirements set out in the Regulations and guidance.
HMRC has produced a useful guide for estate agents to ensure
they are compliant with the Regulations. This guidance was updated in October 2020 and can be found 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. If you are unsure how to edit or adapt this template policy in accordance with the Regulations and guidance, professional advice should be sought.
This Estate 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.
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