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What do ID documents tell us?

20th September 2017

Customer Due Diligence (CDD), which forms part of Know Your Customer or KYC, is an important tool in the estate agent’s armoury when it comes to fulfilling their obligations under the Money Laundering Regulations.

When taking on new listings from vendors and putting offers forward for purchasers agents must demonstrate they have assessed any risk the relationship presents to their business from a Money Laundering point of view.

It is easy to get hung up on getting hold of photo ID, or utility bills but agents must challenge themselves to understand what it is the documentation is telling them about any perceived risk.

Client verification is one part of that process. Quite often it is the transaction itself that is more likely flag Money Laundering risk.

Know Your Customer is about identifying the individual(s) involved in the sale or purchase and understanding more about the nature of the transaction.

HMRC acknowledge that in most cases this will be self-evident but does provide some guidance on what to look out for including:

  • Unusual aspects of the relationship
  • Residency in high risk part of the country (e.g. London)
  • Unusual payment or purchase method (complicated business structures)
  • Significant cash assets*

This list is not exhaustive, nor is it hard and fast evidence of illegal activity, but rather indicative behaviours of individuals who may be involved in money laundering.

Critically in order to remain compliant, HMRC require agents to “have a system for keeping copies of customer due diligence and supporting records and to keep the information up to date”*

Landmark have long advocated electronic checks over traditional paper as a more reliable and consistent tool to apply Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD), and investigate transactions to demonstrate KYC.

Compliance in a Box provides a range of compliance tools under one roof including:

  • Electronic AML checks to apply CDD
  • Identify PEPs and those on sanctions lists
  • Foreign national checks for non-UK based clients
  • Land Registry title information to verify property ownership
  • Company checks to identify beneficial owners
  • Retained copies of all documentation with time & date-stamped audit trail for MLRO

Make sure you fully understand your transactions, mitigate your AML risk, and save your business time, with Compliance in a Box. Sign up below to register for your Landmark account, or contact us on 01524 220013 / eas@landmark.co.uk

*Source: Anti Money Laundering Supervision: Estate Agency Businesses (view here)

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