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ANTI-MONEY Laundering (AML) Policy

ANTI-MONEY LAUNDERING (AML) POLICY
Lara Letting Limited

1. Introduction
This Anti-Money Laundering (AML) Policy outlines the measures that Lara Letting Limited will take to prevent and detect money laundering and terrorist financing activities in accordance with the relevant laws and regulations, including the UK’s Proceeds of Crime Act 2002 (POCA), Terrorism Act 2000, and the Money Laundering, Terrorist Financing, and Transfer of Funds Regulations 2017.

The purpose of this policy is to safeguard Lara Letting Limited, its employees, clients, and partners from being used for money laundering purposes and to ensure compliance with AML obligations.

2. Scope of the Policy
This policy applies to all employees, agents, contractors, and business associates of Lara Letting Limited. It covers all aspects of the company’s operations, including:

  1. Tenant onboarding
  2. Rent payment systems
  3. Landlord and tenant financial transactions
  4. Property management activities

3. Legal Framework
Lara Letting Limited complies with the UK AML regulations. The primary UK Legislation covering anti-money laundering and counter-financing of terrorism includes:

  1. The Proceeds of Crime Act 2002 (POCA)
  2. The Terrorism Act 2000
  3. The Money Laundering, Terrorist Financing, and Transfer of Funds (Information on the Payer) Regulations 2017
  4. The Criminal Finances Act 2017
  5. Terrorist Asset-Freezing Act 2010
  6. Anti-terrorism, Crime and Security Act 2001
  7. The Money Laundering and Terrorist Financing (Amendment) (High Risk Countries) Regulations 2021

We also follow relevant guidance provided by the Financial Conduct Authority (FCA) and the National Crime Agency (NCA).

4. Roles and Responsibilities

  1. Money Laundering Reporting Officer (MLRO): The MLRO is responsible for overseeing the implementation of the AML policy and ensuring that all staff are trained and familiar with the regulations. The MLRO will also monitor suspicious activity and report it to the appropriate authorities.
  2. Reporting Officer – Robert Allan: Robert Allan is designated as the Reporting Officer for Lara Letting Limited. Robert is responsible for evaluating any suspicious activity reports (SARs) submitted by employees and ensuring timely filing with the National Crime Agency (NCA). He will also act as the primary point of contact for any internal or external queries regarding suspicious transactions.
    1. Contact for Reporting Suspicious Activity:
      Email: info@laraletting.co.uk
  3. Staff: All staff must be familiar with the company’s AML procedures, report any suspicious activity, and cooperate with compliance efforts.

5. Risk-Based Approach
Lara Letting Limited will conduct risk assessments for both tenants and landlords to assess the potential for money laundering and terrorist financing. Factors considered in the risk assessment include:

  1. The source of funds
  2. The geography of the client or tenant (e.g., high-risk jurisdictions)
  3. The nature of the property transactions
  4. The transaction volume and frequency

Based on the outcome of the risk assessment, enhanced due diligence (EDD) will be conducted for high-risk clients.

6. Customer Due Diligence (CDD)
As part of the tenant and landlord onboarding process, Lara Letting Limited will perform the following CDD measures:

  1. Verification of Identity: Obtain and verify identification documents, such as passports, driving licenses, and utility bills.
  2. Verification of Source of Funds: Assess the source of funds for rental payments or property transactions. This could include bank statements, tax returns, or proof of employment/income.
  3. Ongoing Monitoring: Continuously monitor the rental payments and transactions for unusual activity.

7. Enhanced Due Diligence (EDD)
If a tenant or landlord is deemed to be high-risk, Lara Letting Limited will apply Enhanced Due Diligence (EDD). This could include:

  1. Obtaining additional documentation or information to confirm identity and the source of funds.
  2. Conducting a more detailed background check to ensure the individual or entity is not involved in illegal activity.
  3. Monitoring the individual’s transactions more closely.

8. Record Keeping
All records related to AML checks, including identity verification, risk assessments, and transaction histories, will be securely maintained for a minimum of five years. These records will be readily available for inspection by regulatory authorities.

9. Reporting Suspicious Activity
If any employee suspects that money laundering or terrorist financing may be occurring, they must report it immediately to the Reporting Officer, Robert Allan, via email at info@laraletting.co.uk. Robert will evaluate the situation and, if necessary, file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).

10. Staff Training
All employees of Lara Letting Limited will undergo AML training upon joining the company and at regular intervals thereafter. The training will cover the following topics:

  1. The identification of money laundering and terrorist financing risks
  2. How to conduct proper customer due diligence (CDD)
  3. How to spot and report suspicious activity
  4. Legal obligations under AML laws

11. Breach of Policy
Failure to comply with this AML policy may result in disciplinary action, including dismissal. Any employee found to be involved in money laundering or terrorist financing will be reported to the relevant authorities.

12. Review and Update of Policy
This policy will be reviewed and updated at least annually or whenever there are significant changes in relevant laws or the company’s operations. Updates will be communicated to all staff and stakeholders.