Money Laundering Policy Statement
Parfitt Properties Limited trading as Marcus Parfitt is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) regulations 2017.
Parfitt Properties Limited trading as Marcus Parfitt are registered with HMRC for anti-money laundering supervision under the Money Laundering Regulations.
Risk sensitive policies and procedures have been established in order to anticipate and prevent money laundering and terrorist financing.
A risk sensitive or risk-based approach is where businesses assess the risk of customers laundering money through their business. Whilst Parfitt Properties Limited trading as Marcus Parfitt take the starting point that most customers will not launder money we do identify criteria that may indicate a higher risk of money laundering – e.g. where there is no face-to-face meeting to establish identity.
Parfitt Properties Limited trading as Marcus Parfitt is committed to staff training in anti-money laundering legislation and this is also covered as a part of the induction of all new staff.
The Parfitt Properties Limited trading as Marcus Parfitt MLRO is Paulett Lewis based at the 28 Church Row, Hampstead Village, London, NW3 6UP office, who will forward reports to NCA as necessary. Her Deputy is Marcus Parfitt also based at the Hampstead office.
Adherence to the "Customer Due Diligence" identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism.
It is Parfitt Properties Limited trading as Marcus Parfitt policy that all vendors and purchasers must be identified fully with a minimum of two forms of ID, evidence of identity being photographic and also evidence of residence e.g. a utility bill dated in the last three months.
Alternatively, or additionally in the case of extended due diligence, an approved online money laundering check must be made with an approved supplier.
Seller clients will be identified before Parfitt Properties Limited trading as Marcus Parfitt enter into a business relationship and purchasers will be identified at the time a transaction is agreed, subject to contract.
Should a face to face meeting not take place then enhanced due diligence procedures will need to be adopted by asking for additional information or evidence to establish the customer's identity, and ensuring that the documents supplied are certified. It would also be prudent to ensure that any first payments are made to a bank account in the customer's name.
If the verification of the customer's identity is done by documents this should be based on:
A government issued document with the customer's full name and photo with either the customer's date of birth or residential address such as:
- Valid passport
- Valid photocard driving licence
- National identity card
- Firearm's certificate
A government issued document (without a photo) which includes the customer's full name and supported by secondary evidence:
- Old style driving licence
- Recent evidence of entitlement to state or local authority-funded benefit such as housing benefit, council tax benefit, pension, tax credits
Supported by secondary evidence such as:
- A Land Registry title search
- A recent utility bill
- Bank or building society statement
- Most recent mortgage statement from a recognised lender
As part of Customer Due Diligence (CDD) process a check will be made of the PEP and Sanctions register. If an individual is a PEP or has sanctions then the enhanced due diligence procedure will apply.
For customers other than private individuals.
For customers who are not private individuals, such as corporate customers and private companies, the business must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company - a search at Companies House will reveal details of directors and company secretary (PSC register).
The above requirements for documentation will be applied to all shareholders or those holding voting rights at 25% or more of a business.
Suspicious Activity Reporting
A report should be made if a member of staff/ the nominated officer thinks that there is a possibility, which is more than fanciful, that a person is or has been engaged in money laundering or terrorist financing.
The report should be made to Paulett Lewis, the Parfitt Properties Limited trading as Marcus Parfitt Money Laundering Reporting Officer,(or her deputy Marcus Parfitt) at the Hampstead office as soon as is practicable.
Once the MLRO has considered the matter, a suspicious activity report may be raised with the National Crime Agency (NCA).
What is Suspicious Activity
This list is by no means exhaustive but includes:
- Reluctance to provide details of their identity
- Customer is trying to use intermediaries to hide their identity or involvement
- There appears to be no genuine reason for the customer using the business's services
- Lack of evidence (or an avoidance in disclosure) of the source of funds
- Money is paid by a third party who does not appear to be connected with the customer
- The customer requests payment to a third party who has no apparent connection with the customer
- A cash transaction is unusually large and the customer will not disclose the source of funds
- A transaction is carried out for less than market value with an unconnected person
- Should a report be made then it is important that this fact, and any information about the transaction in question, is kept confidential
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.
The purpose for keeping these records is to demonstrate the business's compliance with the regulations and to aid any resulting investigations.