1. Introduction:
Citystay Property Agents Ltd is committed to preventing money laundering and terrorist financing activities through its operations. This Anti-Money Laundering (AML) Policy outlines our commitment to complying with all applicable laws and regulations related to anti-money laundering and counter-terrorism financing in the United Kingdom. The Money Laundering Reporting Officer (MLRO) at Citystay Property Agents Ltd is Declan Fitzhenry, the Managing Director. He is responsible for maintaining, managing and monitoring the policies, controls and procedures in respect of Anti-Money Laundering.
2. Purpose:
The purpose of this policy is to establish procedures and controls to prevent Citystay Property Agents Ltd from being used for money laundering or terrorist financing activities. This policy applies to all employees, contractors, and agents acting on behalf of Citystay Property Agents Ltd.
3. Legal and Regulatory Framework:
Citystay Property Agents Ltd will comply with all relevant laws and regulations, including but not limited to:
- The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
- Proceeds of Crime Act 2002.
- Terrorism Act 2000.
- Criminal Finances Act 2017.
- Terrorist Asset-Freezing Act 2010.
- Anti-Terrorism, Crime & Security Act 2001.
- Counter Terrorism Act 2008, Schedule 7.
- Sanctions regulations.
- Other relevant legislation and regulatory guidance issued by HM Revenue & Customs (HMRC) and the Financial Conduct Authority (FCA)
4. Risk-Based Approach:
Citystay Property Agents Ltd will adopt a risk-based approach to identify, assess, and mitigate the risks of money laundering and terrorist financing associated with its activities. This includes:
- Conducting risk assessments to identify and evaluate potential risks.
- Implementing appropriate customer due diligence (CDD) measures based on the assessed risks.
- Monitoring transactions and customer relationships for suspicious activities.
- Reporting suspicious activities to the National Crime Agency (NCA) through the Suspicious Activity Reporting (SAR) regime.
5. Customer Due Diligence (CDD):
Citystay Property Agents Ltd will conduct CDD measures on all customers to verify their identities and assess the risks associated with the business relationship. This includes:
- Obtaining identification documents from customers, such as passports or driving licenses.
- Verifying the source of funds.
- Verifying the identity of customers through reliable and independent sources.
- Conducting enhanced due diligence (EDD) on high-risk customers, politically exposed persons (PEPs) – relations of PEPs, and complex transactions.
6. Record-Keeping:
Citystay Property Agents Ltd will maintain accurate and up-to-date records of all customer transactions, including identification documents, transaction records, and any other relevant information. Records will be retained for at least five years as required by law.
7. Training and Awareness:
Citystay Property Agents Ltd will provide regular training and awareness programs to employees, contractors, and agents to ensure they understand their obligations under this AML Policy. Training will cover topics such as recognising suspicious activities, customer due diligence procedures, and reporting requirements.
8. Reporting Obligations:
Employees, contractors, and agents of Citystay Property Agents Ltd are required to report any suspicions of money laundering or terrorist financing to the designated Money Laundering Reporting Officer (MLRO) promptly. Reports will be investigated and, if necessary, reported to the National Crime Agency (NCA) through the Suspicious Activity Reporting (SAR) regime.
9. Compliance Monitoring:
Citystay Property Agents Ltd will establish procedures to monitor compliance with this AML Policy and applicable laws and regulations. Regular reviews and audits will be conducted to assess the effectiveness of controls and identify areas for improvement.
10. Non-Retaliation:
Citystay Property Agents Ltd prohibits retaliation against employees, contractors, or agents who report suspicions of money laundering or terrorist financing in good faith. Any instances of retaliation will be subject to disciplinary action.
11. Review and Updates:
This AML Policy will be reviewed annually and updated as necessary to reflect changes in laws, regulations, and business practices.
12. Implementation:
All employees, contractors, and agents of Citystay Property Agents Ltd are responsible for complying with this AML Policy. Failure to comply may result in disciplinary action, including termination of employment or contractual relationships.
13. Contact Information:
For questions, concerns, or reporting suspicious activities, employees, contractors, and agents may contact the designated Money Laundering Reporting Officer (MLRO) at declan@citystaypropertyagents.co.uk
Citystay Property Agents Ltd Reg. No. 15622405 – Anti Money Laundering Policy 2024