Anti-Money Laundering Policy & Risk Assessment

Effective date: 1 May 2025 · Reviewed annually · Next review due: 1 May 2027

1. Purpose

This policy sets out how Tessa Lang Property Ltd complies with anti-money-laundering (AML) legislation in the United Kingdom. It applies to all staff involved in property lettings, sales and property-management services. The purpose is to prevent the firm being used to facilitate money laundering or terrorist financing.

2. Legal Framework

This policy is based on:

  • The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).
  • The Proceeds of Crime Act 2002 (POCA).
  • The Terrorism Act 2000.
  • HMRC Guidance for Estate Agency Businesses.
  • Propertymark AML Guidance.
3. Responsibilities

The firm's Money Laundering Reporting Officer (MLRO) is:

Tessa Lang, Director
Email: info@tessalangproperty.co.uk
Telephone: 020 7352 5386

All employees must report suspicious activity to the MLRO without delay.

4. Risk-Based Approach

We adopt a risk-based approach to assessing and managing money-laundering risks, focusing resources on areas of highest threat.

4.1 Firm-Wide Risk Assessment

Risk AreaRisk LevelRationale
Client typeMediumMost clients are private landlords and tenants; occasional company lets increase risk.
Property valueLow–MediumGenerally average-value London residential properties.
Geographic riskMediumLondon-based business, but may have clients based overseas (including high-risk jurisdictions).
Delivery channelsMediumMix of remote and face-to-face interaction; remote increases identity risk.
PaymentsMediumRent and deposits processed through client account; risk of third-party payments.
Lettings vs. salesMediumLettings less risky than sales, but still vulnerable to layering or criminal tenants.
5. Customer Due Diligence (CDD)

We conduct Customer Due Diligence (CDD) before entering into a business relationship. This includes:

5.1 Individuals

  • Photographic ID (passport or driving licence).
  • Proof of address (utility bill or bank statement — under 3 months old).

5.2 Companies

  • Certificate of incorporation.
  • Proof of address for business and directors.
  • Identification of beneficial owners (over 25% shareholding).

5.3 Enhanced Due Diligence (EDD)

Applied when:

  • The client is based in a high-risk third country.
  • The client is a politically exposed person (PEP) or linked to one.
  • There are complex or unusually large transactions.

EDD includes verifying the source of funds and source of wealth.

6. Ongoing Monitoring
  • We monitor transactions and relationships for unusual or suspicious activity.
  • We renew CDD if there is a material change or every 12 months for ongoing relationships.
7. Record Keeping

We retain all AML documentation and records for a minimum of five (5) years after the end of the business relationship.

8. Reporting Suspicious Activity

Any staff member suspecting money laundering must report internally to the MLRO using the Internal Suspicious Activity Report (SAR) form.

The MLRO will consider and, if necessary, submit a report to the National Crime Agency (NCA).

9. Training

All relevant staff are trained on AML procedures:

  • On induction.
  • Annually thereafter.
  • Whenever legislation or risk factors change.
10. Internal Controls and Audit

We maintain appropriate internal controls including:

  • Documented procedures.
  • Staff access restrictions.
  • AML training logs.
  • Periodic internal audits.
11. Breaches and Disciplinary Action

Failure to comply with this policy is a disciplinary offence and may be reported to the relevant authority.

12. Policy Review

This policy will be reviewed annually or in response to:

  • Legislative changes.
  • Regulatory guidance.
  • Internal incident or audit findings.

Approved by: Tessa Lang, Director