As with all Estate Agents, Whittaker’s Estate Agents are subject to the Money laundering Regulations 2007 to counter money laundering activities and terror financing activities. This means we have a legal obligation to obtain and hold identification and proof of address for all our customers. Additionally we are also required to establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place.
Managing the Risk
We take a risk sensitive approach throughout our business in order to anticipate and prevent such activities. We take as a starting point that most customers will mot launder money however we aim to identify criteria that would indicate a higher risk of money laundering. All high risk assessment results will be pasted onto our Money Laundering Reporting Officer who will report any suspicious activity in a Suspicious Report (SAR) to the National Crime Agency as necessary
Adherence to the ‘Due Diligence’ identification procedure on every occasion will mitigate the risk of our business being used to launder money or fund terrorism. All vendors and purchasers must be identified fully with forms of ID, evidence of identity being photographic along with evidence of residence (acceptable forms listed below). All vendors and purchasers will be required to present these in person at our office where they will be validated and copied as required. It is our policy to only deal with customers face to face however should this form of communication not be available then an ‘Enhanced Due Diligence’ procedures will need to be adopted through additional information / evidence ensuring that that the documents supplied are certified.
Acceptable forms of Individuals Identification
- Current signed passport
- Current UK or EEA photocard driving licence
- Current UK full (old style) driving licence
- Photographic registration card for self-employed individuals in the construction industry – CIS4
- Benefit book or original notification letter from Benefits Agency
- Firearms or shotgun certificate
Acceptable forms of Proof of address
- Current UK driving licence (but only if not used for the name evidence)
- Benefit book or original notification letter from Benefits Agency (but only if not used for the name evidence)
- Utility bill (gas, electric, satellite television, landline phone bill) issued within the last three months
- Local authority council tax bill for the current council tax year
- Bank, building Society or Credit Union statement or passbook dated within the last three months
- Original mortgage statement from a recognised lender issued for the last full year
- Solicitors letter within the last three months confirming recent house purchase or land registry confirmation of address
- HMRC self-assessment letter or tax demand dated within the current financial year
- NHS Medical Card or letter of confirmation from the GP’s practice of registration with the surgery
If you are acting as a representative of an estate either executor or administrator we will still require the Individual ID and Proof of address along with
- Grant of Probate (if a Will was left)
- Letter of Administration (if no Will was left)
- Copy of the ‘Death Certificate’
- Copy of the ‘Will’
Other than Private Individuals
For customers who are not private individuals, such as corporate customers and private companies, we 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.
Politically Exposed Person (PEP)
A politically exposed person (PEP) is one who has been entrusted with a prominent public function. A PEP generally presents a higher risk for potential involvement in corruption by virtue of their position and the influence that they may hold, therefore when dealing with a PEP (or their immediate family and close associates) ‘Enhanced Due Diligence’ procedures will need to be adopted.
Suspicious Activity Reporting
As part of our duty to recognise signs of suspicious activity, should we become concerned by the authenticity of any information provided or become suspicious about any aspect of a sale / purchase or that person is or has been engaged in money laundering / terrorist financing, we are legally obliged to submit a ‘Suspicious Activity Report’ (SAR) to the National Crime Agency.
Suspicious Activity Reporting
As part of ongoing compliance with the regulations all records will be kept on file, including records of client identification and their transactions for at least five years from the end of a business relationship with a client. Personal data received from clients is protected by data ?protection law, it will only be used for the purpose of prevention of money laundering / terror financing activities.