Thistles Estate Agents Anti-Money Laundering Risk Assessment and Policy

Introduction

Thistles Estate Agents are committed to complying with the Anti Money Laundering legislation (AML).

This includes:

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017; The Terrorism Act 2000; The Bribery Act 2010; The Proceeds of Crime Act 2002 and; The Criminal Finances Act 2017.

We must take ALL steps necessary to ensure that our business is not used to launder the proceeds of crime or to assist in terrorist financing and we will regularly monitor and review our policies, procedures and training.

Non-compliance will be treated as serious misconduct that could result in an employee’s dismissal and in every case being reported to the Money Laundering authorities.

Further, if there is a failure to comply with the Regulations you may face civil penalties or criminal prosecution which could result in unlimited fines and/or a prison term of up to 2 years or 5 years where there has been ‘tipping off’ (see below). If you are convicted of involvement in any money laundering offence you may face unlimited fines and up to 14 years imprisonment.

Your point of contact:

The Nominated Officer is Eleanor Malpas who is responsible for maintaining, managing and monitoring our policies and procedures and for dealing with any suspicious activity reports (SAR) to the National Crime Agency (NCA) with whom we are registered.

The Nominated Officer shall review the policies and procedures contained within this document on an annual basis.

On occasions where Eleanor Malpas is not available due to annual leave or sickness leave the deputy Nominated Officer is Debbie Hepburn.

Reviewed September 2020.

Senior Managers, such as the CEO and CFO, are responsible for the oversight of compliance with the Regulations and can be held personally liable if they don’t take the steps necessary to protect the business from money laundering and terrorist financing.

Senior Managers must:

• Identify, assess and manage effectively, the risks that the business may be exploited to launder money or finance terrorists
• Take a risk based approach to managing these risks that focuses more effort on high risks
• Appoint a nominated officer to report suspicious activity to NCA
• Devote enough resources to address the risk of money laundering and terrorist

financing

• Ensure that the business has carried out a risk assessment for the business and has

policies, controls and procedures to help reduce the risk that criminals may exploit

the business for financial crime

• carry out a risk assessment identifying where our business is vulnerable to money laundering and terrorist financing
• take a risk-based approach to managing these risks which will focus more effort on higher risks
• prepare, maintain and approve a written policy statement, controls and procedures to show how the business will manage the risks of money laundering and terrorist financing identified in risk assessments
• review and update the policies, controls and procedures to reflect changes to the risks faced by the business
• make sure there are enough trained people equipped to implement policies adequately, including systems in place to support them
• monitor effectiveness of the business’s policy, controls and procedures and make improvements where required
• have systems to identify when you are transacting with persons from or based in high risk third countries identified by the EU, FATF, HMT or financial sanctions targets advised by Office of Financial Sanctions Implementation and take additional measures to manage and lessen the risk
• approve the establishment, or continuation, of a business relationship with a politically exposed person or a family member or known close associate of a politically exposed person
• devote enough resources to deal with money laundering and terrorist financing.

The risk assessment and policies, controls and procedures should be reviewed in response to changes to our business, the market, and information from HMRC or changes to the legislation otherwise at least, on an annual basis.

Eleanor Malpas has been appointed as the Compliance Officer who is responsible for our compliance with the regulations including:

Reviewed September 2020.

• Carrying out regular audits on compliance with the regulations such as: actively checking adherence to the policies, controls and procedures; reviewing how effective these are; recommending and implementing improvements following such reviews
• Ensuring compliance throughout the business with anti-money laundering legislation and internal policies, controls and procedures
• Oversight of the screening of relevant staff