Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
Our policy & procedures
Calder Colbourne and Dixon Limited trading as Calders Residential is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Risk assessments will be carried out within our policies and procedures to help prevent money laundering and terrorist financing.
This risk based approach is where we assess the risk of customer’s laundering money through our business activities. Although we accept that the majority of our customers will not launder money, we must identify criteria that would indicate a higher risk of money laundering. An example of this is where we do not meet the client face-to-face at any point during the transaction.
As part of mitigating the risk Calders Residential recognises that it is essential for all staff to receive training in anti-money laundering legislation and as such all staff are trained to understand the company’s responsibilities and how to identify risk. Each member of staff is also provided with a copy of this Money Laundering Policy as a reminder of their responsibilities and where/how to report suspicious circumstances.
Our nominated Money Laundering Reporting Officer (MRLO) is Andrew Calder who is responsible for making a decision as to whether further due diligence is needed or a report should be made to The National Crime Agency. If it is decided that a report must be made it is the responsibility of our MRLO to file the report with The National Crime Agency (NCA).
Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism. We recognise that under the regulatory guidance we can do this by either taking paper documentation or running an appropriate electronic Anti Money Laundering check.
The regulations identify that “Due Diligence” should be carried out on our “Client” and are required because we deal with one off transactions of £15000 or more. The customer we must identify is the beneficiary of the transaction, identified as anyone who owns or controls 25% or more of the property. Therefore all will be subject to Anti Money Laundering check. Should the check be unsuccessful we will then seek further identification through approved documentation.
This policy and our procedures will be reviewed periodically to ensure they adequately reflect the risk of money laundering to the company.
We will collect documents in line with the following which is stipulated by the regulatory guidance.
Like all estate agents in the UK, Calders Residential have to obtain and hold identification and proof of address for all customers.
We are also required to establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place, therefore we would request that you identify anyone who you would consider to be a beneficial owner.
Where appropriate, the source or destination of funds may also be requested. Without this information we will be unable to proceed with any work on your behalf.
Individual identity documents
Calders Residential will require one form ‘identification’ and one form of ‘proof of address’. The list below should give you a guidance of what type of identification and proof of address will be acceptable.
Identity
- Passport
Has to be current and signed - UK driving licence
Valid, Full or Provisional
Proof of address
- UK/EU/EEA Drivers Licence (if UK Drivers Licence not used as ID)
Must be valid, not expired. Photo only. Full or provisional. - Bank, Building Society Statement
Dated with 3 months. Must include account number and show recent activity. No general correspondence. - Credit Card Statement
Dated within 3 months. Must include account number and show recent activity. No general correspondence. - UK, EU, EEA Mortgage statement
Dated within 12 months. Must show account number. No general correspondence. - Utility Bill
Dated within 6 months E.g. Gas, electricity, water. Must show address for service and/or account number. No general correspondence. - Council Tax
Dated within 12 months. Must show address for service and/or account number. No general correspondence. - Benefits Entitlement Letter
Dated within 12 months. Issued by DWP or Jobcentre plus. Must confirm benefit payable at time of issue. E.g. Pension, disability, single parent, housing etc. - HMRC Tax Notification
Dated with 6 months. Must state national insurance number and tax calculation. No general correspondence.
Probate
If you are acting as a Representative of an Estate we require the following:
- Grant of Probate (if a will was left)
- Letter of administration (if no will left)
- Individual identity evidence from List A & B for the Personal Representative, either executor or administrator
Limited company
If you are acting as a Representative of a UK Company we will also require the following:
- Certificate of Incorporation
- Articles of Association
- Memorandum of Association
- Latest Annual Return or Confirmation Statement, with details of current company officers
- If offshore, nominee director declaration and a general power of attorney
- Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company
If you are acting as a Representative of an Offshore Company we will also require the following:
- Certificate of Incorporation
- Articles of Association, Memorandum of Association, Latest Annual Return with details of current company officers, Share Certificate(s) showing the Ultimate Beneficial Owner OR
- Certificate of Incumbency
- If the shares are owned by another company, repeat steps above for the holding company
- Nominee director declaration and/or general Power of Attorney (if applicable)
- Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company
Trust
If you are acting as a Representative of a Trust we require the following:
- Trust deed
- List of trustees
- List of beneficiaries
IF YOU ARE UNABLE TO DELIVER DOCUMENENTS TO OUR OFFICE IN PERSON, AND DECIDE TO EMAIL THEM TO US, WE REQUEST EACH DOCUMENT IS SENT INDIVIUALLY TO TRY TO REDUCE THE RISK OF INTERCEPTION/ONLINE FRAUD. WE DO NOT ACCEPT ANY RESPONSIBILITY FOR LOST OR INTERCEPTED DOCUMENTS.
Suspicious Activity Reporting.
WARNING: We will report all suspicious activity to The National Crime Agency (NCA)
Reviewed April 2023
