Sanctions and Anti-Money Laundering Policy

1. Introduction

 

Unique London Property Management Ltd is a UK registered company providing property management services. The business of the Company is low risk in relation to money laundering, however in order to prevent any of our services being used (or potentially used) for any money laundering activity, as well as any of our staff being exposed to money laundering, we wish to put in place the following policy which supplements the sanctions and/or anti-money laundering training given to all members of staff.

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2. Scope of the Policy

 

The broad definition of money laundering means that potentially anyone could commit a money laundering offence, this includes all employees of the Company, all temporary staff and contractors. Our policy is to enable the Company to meet its legal and regulatory requirements in a way which is proportionate to the low risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring. All employees must be familiar with their legal responsibilities.

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3. What are Sanctions and Money Laundering Reporting?

 

The principal primary legislation is The Proceeds of Crime Act 2002 (POCA), which consolidated, updated and reformed criminal law with regard to money laundering, supplemented by the Terrorism Act 2000 and the Fraud Act 2006. The principal secondary legislation is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019.

 

Money laundering can be defined as the process to move illegally acquired cash through financial systems so that it appears to be from a legitimate source. Money laundering offences include: concealing, disguising, converting, transferring criminal property or removing it from the UK (Section 327 POCA); entering into or becoming concerned in an arrangement which you know or suspect facilitates the acquisition, retention, use or control of criminal property by or on behalf of another person (Section 328 POCA); and acquiring, using or possessing criminal property (Section 329 POCA).

 

There are also several secondary offences, failure to disclose knowledge or suspicion of money laundering to the Money Laundering Reporting Officer (MLRO); failure by the MLRO to disclose knowledge or suspicion of money laundering to the National Crime Agency; and ‘tipping off’ whereby somebody informs a person or persons who are, or who are suspected of being involved in money laundering, in such a way as to reduce the likelihood of their being investigated or prejudicing an investigation.

 

Any member of staff could potentially be caught by the money laundering provisions, if they suspect money laundering and either become involved with it in some way, and/or do nothing about it. This Policy sets out how any concerns should be raised.

 

UK sanctions changes apply to letting agents with effect from 14th May 2025. These changes are implemented under the Sanctions and Anti Money Laundering Act 2018 (SAMLA). These changes mean all landlords and tenants require UK sanctions checks for rents of more than 30 days. This encompasses all Assured Shorthold Tenancies (AST) so all landlords are to be checked

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4. Sanctions and Money Laundering Reporting Officer (MLRO)

 

The company is not required to register for AML at this time. However, queries relating to regulation can be addressed to the responsible officer for the company Arzu Uygun and can be contacted at the address below.

 

5. Sanctions checks that return a positive result

 

Any checks not considered low risk must be referred to the directors and the transactions paused whilst the director refers

 

6. Consideration of the Disclosure by the MLRO

 

Once the MLRO has received the report, it must be evaluated in a timely manner in order to determine whether a report should be made to the OFSI.

 

7. Customer Identification and Due Diligence

 

Due diligence is performed on all landlords and tenants who continue on to rent a property. They must provide basic information including  Full Name  Date of Birth  Address  Contact details

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8. Ongoing Monitoring

 

Staff should review customers at regular intervals to ensure that the risk level of each customer information and information held on each customer is not only accurate and up to date but is consistent with the knowledge of the customer and its business. Where Biometric reporting has been obtained this should include ongoing monitoring notifications by the 3rd party reporting provider.

 

9. Data Protection

 

Customer details must be collected in accordance with the Data Protection Act 2018. This data can be “processed” as defined under the Data Protection Act 2018 to prevent money laundering and terrorist financing.

 

10. Record Keeping

 

Customer identification evidence and details of any relevant transaction(s) for that customer must be retained for at least 6 years from the end of any business relationship with that customer.

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Risk Assessment for AML and UK Sanctions Compliance

 

Overall Risk Assessment: Unique London Property Management Ltd is LOW risk.

 

Unique London Property Management Ltd (the Company) is a UK registered company providing letting agent services.

 

The Company is not regulated by HMRC in relation to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 as amended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 and therefore is not prescribed to have a formal anti-money laundering (AML) risk assessment in place. The Company considers itself to be [low] risk in relation to the risk of money laundering.

 

However, to supplement our Sanctions and AML policy and the training given to all members of staff, the Company considers it prudent to consider the risks of its business type being a letting agent. As such, the Company has decided to put in place a risk assessment of the Company as a whole that will identify areas that may be most exposed to money laundering and terrorist financing and how the Company will mitigate these risks.

 

This risk assessment was carried out on behalf of the company by the directors April 2025.

 

In preparing this Risk Assessment, the Company has:

 

1. considered the size and nature of its business;

2. identified the key money laundering and/or sanctions risks faced by the Company;

3. assessed and considered the risk impact if they do occur;

4. reviewed its systems and controls in place in order to mitigate any risk and bring the level to an acceptable level;

 

This assessment will be reviewed annually or when necessary.

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