Leary & Co is has adequate controls to counter money laundering activities and terrorist financing activities in line with the Money Laundering Regulations 2007. The below information has been taken from the OFT Money Laundering Regulations 2007 Core guidance issued under Crown Copyright 2007
Policies and procedures have been implemented to prevent money laundering and financing of terrorist activities. Full training will be provided to existing and new employees in anti money laundering legislation.
The head office in Birmingham has a dedicated Money Laundering Reporting Officer. The Money Laundering Officer will forward suspicious activities and report to the National Crime Agency (NCA) if suspicious activity is discovered.
In order to mitigate the risk of money laundering Due Diligence will be conducted on buyers and sellers of property. Two forms of ID, evidence of identity being photographic and also evidence of residence, for example, a utility bill will be required.
If a face-to-face then enhanced due diligence procedures will need to be adopted by asking for additional information or evidence to establish the customer’s identity.
In order to verify a customer’s identity we will require a government issues document displaying the customer’s full name, date of birth, photograph and residential address.
- Driving licence
- National I.D. Card
- Utility bill
- Bank statement
- The most recent mortgage statement
Companies should supply company registration number, registered address and evidence that the individuals have the authority to act for the company – a search at Companies House and/or CreditSafe will reveal details of directors and company secretary.
The nominated officer will create a report if he/she believes that an individual is or has been engaged in terrorist financing activities and/or money laundering. The report will be made to the Office Money Laundering Reporting Officer.
- Not wanting to provide identify documentation
- The use of intermediaries to hide their identity
- The customer doesn’t appear to have an honest reason for using the organisations business services.
- Money is paid by a third party person/company
- The customer requests payment to a third party
- Unusually large cash transactions and the client will not disclose the source of funds
- A transaction is carried out for less than market value with an unconnected person
The following records are required to be kept for 5 years:
- Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed.
- Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed.
By keeping the records for 5 years we demonstrate the business’s compliance with UK regulations.