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Agents - are there gaps in your AML process?

A compliance expert has warned that even though most agents will have robust anti-money laundering (AML) checks and processes in place, there could still be a few areas where improvement is required or things are falling through potential gaps.

Despite recent large fines to businesses being imposed by HMRC for breaching AML procedures making the property sector ‘acutely aware’ of the importance of following the guidelines, Paul Offley, The Guild of Property Professionals’ Compliance Officer, says that not all agents know what they need to fully demonstrate compliance.

To assist agents, Offley has put together an AML checklist to help identify any ‘gaps’ within their office or business.


The 15 tips are laid out below.

For business owners

1: Have you checked your HMRC Government Gateway account to ensure your business is showing a ‘supervised’ AML status?

2: Do you have an AML risk assessment for your business?

3: Do you have you an AML policy in place which has been reviewed in the last 12 months and able to demonstrate that all members of the team have received a copy of this?

4: Can you demonstrate training for all directors/business owners, even for those who may not be actively involved?

5: Can you demonstrate training for all staff? This should be done on an annual basis at a minimum.

General AML

6: Are you able to demonstrate either legal or beneficial ownership for each seller?

7: Have you a completed risk assessment for each seller and buyer?

8: Can you evidence financial sanctions check for each seller and buyer? 

9: Can you evidence politically exposed person (PEP) checks for sellers and buyers?

10: Have you got ID verification based on risk assessments for all sellers and buyers?

11: Can you demonstrate the source of funding being used by buyers?

12: Have you identified any ‘high risk’ country connection from sellers and buyers?

13: Can you demonstrate ongoing AML monitoring until business transaction ends?

14: Do you have an effective control testing program in place?

15: Could each member of the team give you three examples of a suspicious activity?

Offley commented: “The 15 questions above will help agents to identity potential areas of their AML procedure that requires attention so that they can possibly make changes and work on a plan on how to fill the gaps.”

He added: “Being able to demonstrate the correct AML procedures in the event of an unexpected visit from HMRC is crucial and something that every estate agency should be prepared for to protect their business.

Offley said the key is for all agents to familiarise themselves with the procedures and requirements as much as they can and implement processes that will make AML compliance ‘as easy as possible’.

“It is essential for Money Laundering Officers within the business to be able to demonstrate that they can discharge their duties,” he concluded.


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