Anti Money Laundering Policy | PropVision Estate Agents

Our agency is subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, which aims to counter money laundering and the financing of terrorism. We have a legal duty to obtain identification and proof of address from all our customers, who include homeowners seeking to sell their property, buyers, landlords who wish to rent out their property and tenants. We are also obliged to ascertain whether other beneficial owners are involved on whose behalf the transaction or activity is taking place.

Our agency has adopted a risk-sensitive approach throughout our business to recognise and prevent fraudulent transactions. We use a criteria-based system in order to assess the risk of money laundering.

HOW WE MANAGE THE RISK

Our agency invests heavily in training staff on Anti-Money Laundering legislation, which is covered in our induction course and reviewed on an annual basis to ensure that any new or amended legislation is adhered to. We have our own nominated Money Laundering Reporting Officer (MLRO) and Deputy Officer. It is the responsibility of the MLRO to receive and action reports of suspicious behaviour and activity and to complete and submit a Suspicious Activity Report (SAR) to the National Crime Agency when necessary. Our nominated officer is [Name, Job Title] and our deputy officer is [Name, Job Title].

FINANCIAL SANCTIONS COMPLIANCE

From 14 May 2025, our agency is designated as a relevant firm under UK financial sanctions regulations. This means we are legally required to check all clients against the UK Government's consolidated sanctions list and to report to the HM Treasury Office of Financial Sanctions Implementation (OFSI) if we know or have reasonable cause to suspect that a client has breached financial sanctions regulations. These checks apply to all landlords, tenants, vendors and buyers regardless of the value of the transaction or rental amount.

IDENTIFICATION PROCESS

In order to alleviate the risk of attempted money laundering, we carry out Customer Due Diligence (CDD) on all clients. All landlords, tenants, vendors and buyers must be fully identified by providing photographic ID and proof of address. For landlords and sellers, we also require proof of ownership. All original documents must be witnessed by a member of staff, with a copy retained on file. In cases where an original ID cannot be seen in person, copies must be certified by a solicitor or at the post office. Verification checks must be completed on all individuals who have a vested interest in the transaction. For rent payments, we require the bank account to be in the customer's name. Subject to individual circumstances, we may request further documentation.

INDIVIDUAL IDENTITY DOCUMENTS

We require one document from List A and one from List B from all customers. Where applicable, please ensure documents include full name, address and account numbers and are not provided in the form of general correspondence.

List A – Identity Document Current signed passport Current UK/EU photo driving licence Resident permit issued to EU nationals by the Home Office Inland Revenue tax notification State pension or benefits book/notification letter

List B – Proof of Address Current UK/EU photo driving licence, if not used in List A Council tax bill Benefits entitlement letter Local authority rent card Tenancy agreement Bank statement Utility bill from the last three months Telephone bill (excluding mobile pay as you go) Home or motor insurance certificate NHS medical card or letter from GP confirming registration Police registration certificate

List C – Proof of Ownership Most recent mortgage statement Home or motor insurance certificate Solicitor's letter confirming house purchase, deeds or land registration

List D – Probate If you are acting as a representative of an estate, we require the following: Grant of Probate (if a will was left) Letter of Administration (if no will was left) Individual identity evidence from List A and B for the personal representative, either executor or administrator

LIMITED COMPANY

If you are acting as a representative of a UK company, we will also require the following: Certificate of Incorporation Articles of Association Memorandum of Association Latest Annual Return or Confirmation Statement with details of current company officers If offshore, a nominee director declaration and general Power of Attorney Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company

OFFSHORE COMPANY

If you are acting as a representative of an offshore company, we will also require the following: Certificate of Incorporation Articles of Association, Memorandum of Association, latest Annual Return with details of current company officers, and share certificate(s) showing the Ultimate Beneficial Owner, OR a Certificate of Incumbency If the shares are owned by another company, the above steps are repeated for the holding company Nominee director declaration and/or general Power of Attorney (if applicable) Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company

TRUST

If you are acting as a representative of a trust, we require the following: Trust deed List of trustees List of beneficiaries Individual identity evidence from List A and B for all individuals with a vested interest in 25% or more of the capital and/or those who exercise control over the trust

SUSPICIOUS ACTIVITY REPORTING

At any stage of a transaction, should we have reasonable grounds to suspect that money laundering or terrorist financing is taking place, we are legally obliged to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) at nationalcrimeagency.gov.uk.

Suspicious activity may include: A long-distance transaction where the buyer is purchasing from abroad without viewing the property A transaction or valuation request for a property well below market value Reluctance to provide information to confirm identity Delaying the signing of contracts or providing copies of ID Requesting that we hold cash in the client deposit account Settlements being offered in cash Intermediaries used to conceal the identity of the buyer Funds being sent overseas to a third party No apparent reason for using our agency Late changes to the parties involved in a sale or purchase A significant and unexplained improvement in financial position A reluctance to demonstrate source of funds

ADDITIONAL PEP AND ADVERSE MEDIA CHECKS

We check against the UK Government's consolidated sanctions list to identify politically exposed persons (PEPs) and carry out adverse media screening via publicly available sources, including news publications and online records. We document our assessment and the rationale behind any decisions made, ensuring all sources used are reputable.

RECORDS RETENTION

All customer records and supporting documentation will be reviewed regularly by our data controller, who will determine whether there is a continued requirement to hold such information. In compliance with the regulations, we retain records for the current tax year plus five years following the date of the most recent transaction with our company.