Anti-Money Laundering Policy

Price Taylor LLP proactively prevents the services of Price Taylor LLP from being exploited by criminals and terrorists for money laundering purposes in order to comply with the law and requirements of Price Taylor LLP’s Anti-Money Laundering supervisory authority (HMRC). Protecting Price Taylor LLP and staff from risks associated with breaches of law and supervisory requirements, and from the risk of reputational damage presented by implication in money laundering and terrorist financing activities, and to assist the fight against crime and terrorism.

Price Taylor LLP’s Commitment to Anti-Money Laundering.

  • Neither commercial considerations nor a sense of loyalty to clients shall be permitted to take precedence over Price Taylor LLP’s anti-money laundering commitment.
  • A Partner at Price Taylor LLP is responsible for anti-money laundering compliance, and the supervisory authority has been supplied the name of the responsible person.
  • Price Taylor LLP has reviewed the risks of money laundering and terrorist financing to which Price Taylor LLP is subject.
  • Price Taylor LLP have established and documented, policies and procedures including actions required by all staff to prevent money laundering and terrorist financing in the course of their work.
  • To comply with HMRC’s regulations, Price Taylor LLP’s staff will be regularly and continually trained on Anti-Money Laundering.

Vendors and Purchasers Documentation

Production of original documents is the preferred option, however certified copies are accepted.

Below is a list of acceptable documents (for individuals), and where and how, these can be certified:

Who Can Certify Documents? A person listed below, as long as they are not related to you, live at the same address or in a relationship with you.

The certification should be as follows:

The person certifying the documents must have seen the original and must write above their signature that the copy is a true copy of the original and (if applicable) that the photograph bears a true resemblance. They must print their name, state their capacity, contact details and the date of signature. A company stamp is desirable, but not essential, unless from a solicitor’s or accountancy practice. The solicitor should also print their SRA number.

Deposits and / or Financial Gifts

We have a legal obligation to trace and verify the origin of all deposits and / or financial “gifts”, as well as verifying the identity of all those providing the gift.

Anti-Money Laundering Policy & KYC

Introduction

On 26th June 2017 The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (more commonly referred to as The Money Laundering Regulations 2017) came in to force in the UK.   Under the Regulations it is an offence to trade as an Estate Agent unless registered with HMRC for anti-money laundering supervision.   Price Taylor is registered with the supervisory authority.  To comply with the Regulations Price Taylor regularly and continually trains on Money Laundering / Terrorist Financing / Criminal Finances Act.

Customer Due Diligence & Know Your Customer

Risk sensitive policies and procedures are established in order to anticipate and prevent money laundering and terrorist financing.   A risk-sensitive or risk-based approach is where businesses assess the risk of customers laundering money through their business.   Businesses may take the starting point that most customers will not launder money but will identify criteria that would indicate a higher risk of money laundering – ie., where there is no face to face meeting to establish identity.

Price Taylor has appointed a Money Laundering Reporting Officer (MLRO) whose responsibility it is to receive internal reports and to forward reports to the National Crime Agency as necessary.    The MLRO continually assesses the procedures used and ensures compliance with the Regulations is achieved at all times.

Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risk of our business being used to launder money or fund terrorism.

Acceptable Proof of Identity documents are as follows. You cannot use one form of identification for both name and address. For example if you provide your driving licence as proof of your name you must provide another form of identification for your address, such as a utility bill.  Utility bills must be no older than 3 months. 

Proof of name Proof of address

  • Current signed passport Utility bill (gas, electric, satellite television, landline phone bill) issued within the last three months
  • Original birth certificate (UK birth certificate issued within 12 months of the date of birth in full form including those issued by UK authorities overseas such as Embassies High Commissions and HM Forces) Local authority council tax bill for the current council tax year
  • EEA member state identity card (which can also be used as evidence of address if it carries this) Current UK driving licence (but only if not used for the name evidence)
  • Current UK or EEA photocard driving licence Bank, Building Society or Credit Union statement or passbook dated within the last three months
  • Full old-style driving licence Original mortgage statement from a recognised lender issued for the last full year
  • Photographic registration cards for self-employed individuals in the construction industry -CIS4 Solicitors letter within the last three months confirming recent house purchase or land registry confirmation of address
  • Benefit book or original notification letter from Benefits Agency Council or housing association rent card or tenancy agreement for the current year
  • Firearms or shotgun certificate Benefit book or original notification letter from Benefits Agency (but not if used as proof of name)
  • Residence permit issued by the Home Office to EEA nationals on sight of own country passport HMRC self-assessment letters or tax demand dated within the current financial year
  • National identity card bearing a photograph of the applicant Electoral Register entry
  •  NHS Medical card or letter of confirmation from GP’s practice of registration with the surgery
  • For customers other than private individuals such as corporate customers and private companies we must obtain information that is relevant eg., company registration number, registered address and evidence that the individuals have the authority to act for the company. A search at Companies House will reveal details of directors and company secretary.

For customers acting as a Representative of an Estate we will require the following: 

• Grant of Probate (if a will was left)

• Letter of Administration (if no will was left)

• Individual identify evidence for the personal representative, either executor or administrator.

• Court Order, High Court Writ or Certificate of Appointment (Insolvenc y Appointments)

A SAR (Suspicious Activity Report) is made to the NCA  if there is a possibility which is more than fanciful that a person is or has been engaged in money laundering or terrorist financing. 

What is Suspicious Activity?

The list is by no means exhaustive.

New Customers:

• Reluctance to provide details of their identity;

• Customer is trying to use intermediaries to hide their identify or involvement;

• There appears to be no genuine reason for the customer using the business’s services.

Regular/Existing Customers:

• Money is paid by a third party who does not appear to be connected with the customer

• The customer requests payment to a third party who has no apparent connection with the customer

• A cash transaction is unusually large and the customer will not disclose the source of the funds

• A transaction is carried out for less than market value with an unconnected person.  

Should a report be made then it is important that this fact, and any information about the transaction in question is kept confidential.

Record Keeping

Appropriate records are maintained as required by the Supervising Authority.