Effective date: August 2026
AML Reporting Contact: Andrew Schofield

Purpose

Our business is committed to preventing money laundering and terrorist financing through our sales and lettings activities. All staff must comply with applicable UK anti-money laundering legislation and our internal procedures.

This policy applies to all 8 sales offices and as well as lettings headquarters.

Customer Due Diligence

Before proceeding with a transaction where AML checks are required, staff must obtain and verify appropriate identification and information about the customer.

Depending on the circumstances, this may include:

• Proof of identity and address.
• Verification of the identity of companies, directors and beneficial owners.
• Establishing who ultimately owns or controls a property or transaction.
• Understanding the purpose and nature of the transaction.
• Additional checks where a customer or transaction presents a higher level of risk.

Staff must not knowingly proceed with a transaction where required AML checks have not been satisfactorily completed.

Higher-Risk Situations

Enhanced scrutiny should be applied where appropriate, including where there are:

• Complex or unusual ownership structures.
• Unusual payment arrangements or sources of funds.
• Customers who are politically exposed persons (PEPs).
• Customers or transactions connected with high-risk jurisdictions.
• Unusual or unexplained transactions or behaviour.

Staff should seek guidance from the AML Reporting Contact where they are unsure.

Reporting Suspicion

All employees have a responsibility to remain alert to potential money laundering or terrorist financing.

Any suspicion must be reported promptly and confidentially to:

Andrew Schofield – AML Reporting Contact

Staff must NOT inform the customer or any other unauthorised person that a report or suspicion has been raised, as this could constitute unlawful “tipping off”.

Where appropriate, Andrew Schofield will determine whether the matter should be escalated and/or reported to the relevant authorities, including the National Crime Agency (NCA).

Record Keeping

The company will maintain appropriate records of customer due diligence, risk assessments, transaction information and relevant AML decisions/reports for the period required by law.

Records must be kept securely and made available only to authorised personnel or relevant authorities where legally required.

Staff Responsibilities and Training

All staff involved in sales or lettings must:

• Complete appropriate AML training.
• Follow the company’s AML procedures at all times.
• Remain alert to unusual or suspicious activity.
• Report concerns promptly to Andrew Schofiled.
• Never ignore or deliberately circumvent AML requirements.

Managers are responsible for ensuring that staff within their office understand and follow this policy.

Review

This policy will be reviewed regularly and updated when there are changes to legislation, regulatory guidance, or the company’s business activities.