Anti-Money Laundering Policy

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 require certain businesses, including estate agents and letting agents, to implement anti-money laundering controls. We are registered with HM Revenue & Customs (HMRC) as a supervised business under these regulations.

This policy applies to all directors, employees, and contractors of Essex & London Property Management Group Limited. It covers all aspects of our business operations, including the management of rental properties, the collection and handling of rental income, and our relationships with landlords and local authority clients.

We apply Customer Due Diligence (CDD) measures to verify the identity of our clients and to understand the nature of our business relationships. This includes:

• Verifying the identity of all landlords before entering into lease agreements, using government-issued photographic identification and proof of address.
• Verifying the ownership of properties through Land Registry checks or equivalent documentation.
• Understanding the source of funds where rental income is involved.
• Applying Enhanced Due Diligence (EDD) in higher-risk situations, including where clients are Politically Exposed Persons (PEPs) or where transactions are unusually complex or large.
• Keeping records of all identification documents and verification checks for a minimum of five years after the end of the business relationship.

We conduct ongoing monitoring of our business relationships to ensure that transactions are consistent with our knowledge of the client and their business. This includes reviewing lease agreements, rental payments, and any changes in client circumstances that may indicate increased risk.

All directors and employees are required to report any knowledge or suspicion of money laundering or terrorist financing to our nominated Money Laundering Reporting Officer (MLRO). The MLRO is responsible for assessing all reports and, where appropriate, making a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) via the Suspicious Activity Reports Online system.

It is a criminal offence to 'tip off' a person that a SAR has been made or that a money laundering investigation is underway. All suspicious activity reports are treated with strict confidentiality.

All relevant staff receive training on anti-money laundering obligations, how to recognise suspicious activity, and the procedures for reporting concerns. Training is provided at induction and updated regularly to reflect changes in legislation and guidance.

We maintain records of all customer due diligence measures, supporting evidence, and transaction records for a minimum of five years. Records are stored securely and are available to HMRC or law enforcement agencies on request.

We conduct and maintain a written firm-wide risk assessment to identify and assess the money laundering and terrorist financing risks to which our business is exposed. This assessment is reviewed annually and whenever there are significant changes to our business or the regulatory environment.

We screen all clients and counterparties against HM Treasury's financial sanctions list and other relevant sanctions lists before entering into business relationships and on an ongoing basis. We will not conduct business with any person or entity that is subject to financial sanctions.

This policy is reviewed annually by the senior management of Essex & London Property Management Group Limited and updated as necessary to reflect changes in legislation, regulatory guidance, and best practice. Any breaches of this policy will be investigated and may result in disciplinary action.

Questions regarding this policy should be directed to the Money Laundering Reporting Officer at: Essex & London Property Management Group Limited, 11 Station Road, Harold Wood, Romford, RM3 0BP. Telephone: 0208 419 8865.