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Anti-Money Laundering Policy

Policy, risk assessment and procedures · Version 1.0 · October 2026

Policy · Risk assessment · Customer due diligence · Reporting · Records · Training · Forms

1. Policy statement

Oak & Acre, a trading name of Oak and Acre Estate Agents Ltd (company number applied for, coming soon), is an estate agency business. We have applied to HM Revenue & Customs (HMRC) for anti-money laundering supervision and will publish our registration number here once issued. We are committed to preventing our services being used for money laundering or terrorist financing, and to complying with:

• the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended ("the Regulations");
• the Proceeds of Crime Act 2002 and the Terrorism Act 2000;
• UK financial sanctions, administered by the Office of Financial Sanctions Implementation (OFSI);
• HMRC's anti-money laundering guidance for estate agency businesses.

This policy applies to every director, employee, contractor and agent working for Oak & Acre. Breaching it may be a criminal offence as well as a disciplinary matter.

2. What is in scope

• Sales: every residential and commercial sale we act on. We treat both the seller and the buyer as our customers and carry out due diligence on both.
• Lettings: any letting where the monthly rent is the equivalent of €10,000 or more. As a matter of policy, we also verify the identity of every landlord we act for, whatever the rent.
• Property management: landlord identity and ownership checks on instruction.

3. Responsibilities

Anyone who owns or manages Oak & Acre (beneficial owners, officers and managers) must pass HMRC's fit and proper, or approval, test before the business registers.

4. Business-wide risk assessment

We assess the money laundering and terrorist financing risks our business faces, taking account of HMRC's sector risk assessment and the UK National Risk Assessment. We review it at least once a year, and whenever our services, clients or the law change.

5. Customer due diligence (CDD)

5.1 When we carry out checks

• Sellers and landlords: before we market the property.
• Buyers: as soon as an offer is accepted, and before contracts are exchanged.
• Tenants, where rent is in scope: before the tenancy is agreed.
• Existing clients: again whenever something changes or a concern arises.

5.2 Standard checks for individuals

• Full name, date of birth and residential address.
• Verification from a reliable source: a valid passport or photocard driving licence, plus a recent utility bill, bank statement or council tax bill, or an electronic verification check through our ID verification provider.
• Sellers and landlords: proof of ownership from HM Land Registry.
• Buyers: source of funds, such as a mortgage agreement in principle, bank statements showing the deposit, or a solicitor's confirmation of sale proceeds.
• Screening against the UK sanctions list and for politically exposed persons (PEPs).

5.3 Companies, trusts and other entities

• Company name, number and registered office from Companies House.
• Identity of the directors who instruct us, and of every beneficial owner holding more than 25%.
• For trusts: the trust deed, and the identity of the settlor, trustees and beneficiaries.
• We report any material difference between what we find and the Companies House register of people with significant control, as the Regulations require.

5.4 Enhanced due diligence (EDD)

We apply enhanced checks, approved by the Director, where:

• the client, or a family member or close associate, is a politically exposed person;
• the client or the funds have links to a high-risk third country;
• the transaction is complex or unusually large, or has no obvious economic purpose;
• the purchase is in cash with no mortgage, or funds come from a third party;
• the client is reluctant to give information, or the documents seem doubtful.

Enhanced checks include evidence of source of wealth, extra identity documents, and closer monitoring until completion.

5.5 If checks cannot be completed

We will not act, or will stop acting, for anyone whose checks cannot be completed. The Nominated Officer decides whether a report to the NCA is needed.

5.6 Ongoing monitoring

We keep information up to date and watch for activity that doesn't fit what we know about the client, such as late changes of buyer, a new source of funds, or a request to pay money to a third party.

6. Warning signs

• A buyer who isn't concerned about price, survey results or viewing the property.
• Large deposits or full payments from unexplained sources, or through several accounts.
• Funds from a third party, or from abroad, with no clear connection to the buyer.
• Pressure to complete unusually quickly, or a change of buyer just before exchange.
• A property resold quickly at a very different price.
• Use of complex company or trust structures without a clear reason.
• Reluctance to provide identification or explain where money comes from.
• A landlord who wants rent paid in cash or to an unrelated person.

7. Reporting suspicions

• Staff must report any knowledge or suspicion to the Nominated Officer straight away, using the internal report form in section 10.
• The Nominated Officer decides whether to submit a Suspicious Activity Report to the NCA through the SAR Online portal, and records the reasons either way.
• Where we need consent to continue a transaction, we request a Defence Against Money Laundering and do not proceed until it is given, or the statutory notice period has passed.
• Tipping off is a criminal offence. Nobody may tell a client, or anyone else, that a report has been made or that an investigation is under way.
• Any match against the UK sanctions list is reported to OFSI immediately, and any funds are frozen.

8. Record keeping

We keep copies of identity documents, due diligence records and transaction records for five years after the business relationship ends or the transaction completes. After that we delete them, unless the law or an investigation requires us to keep them longer. Internal suspicion reports and the Nominated Officer's decisions are kept separately and securely, away from client files.

9. Training

Every member of staff receives anti-money laundering training when they join and refreshes it every year. The training covers this policy, the law, warning signs and how to report. We keep a record of who completed it and when.

10. Forms

Client identity checklist

Internal suspicion report

11. Review

This policy and the risk assessment are reviewed at least once a year by the Director and the Nominated Officer. Next review: October 2027.

This policy is a working draft prepared for Oak & Acre. Items in square brackets must be completed, and it should be checked against HMRC's current estate agency guidance before use.