Anti-Money Laundering (AML) Policy
Last Updated – 18th March 2025
1. Introduction
ey up a trading name of EY UP Properties Ltd ("we," "us," or "our") is committed to complying with the UK’s Anti- Money Laundering (AML) regulations, ensuring that our estate agency services are not used for money laundering or financial crime. This policy outlines our obligations and the procedures we follow to prevent money laundering and terrorist financing in accordance with:
• 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’s Estate Agency Business Guidance
As a regulated business, we conduct due diligence on all clients and report any suspicious activity to the National Crime Agency (NCA).
2. Responsibilities Under AML Regulations
We have implemented the following measures to meet our AML obligations:
• Customer Due Diligence (CDD): Identifying and verifying clients before establishing a business relationship.
• Enhanced Due Diligence (EDD): Conducting extra checks on high-risk clients, such as politically exposed persons (PEPs) or transactions involving high-value cash payments.
• Suspicious Activity Reporting (SAR): Reporting suspected money laundering to the NCA.
• Record-Keeping: Maintaining client records for at least five years.
• Training: Ensuring all staff receive AML training to recognise suspicious activity.
3. Customer Due Diligence (CDD) Requirements (Appendix A)
Before engaging in a property transaction, we must verify the identity of:
• Buyers
• Sellers
• Landlords
• Tenants (where applicable)
4. Reporting Suspicious Activity
If we suspect money laundering, we will:
• File a Suspicious Activity Report (SAR) with the National Crime Agency (NCA).
• Avoid informing the client (Tipping Off is Illegal) under Section 333A of POCA.
Indicators of suspicious activity include:
• Reluctance to provide ID or proof of funds
• Overseas payments from unrelated third parties
• Transactions below reporting thresholds to avoid scrutiny
• Unusual urgency in completing transactions
5. Record-Keeping
We must retain:
• Client identity records for five years after the transaction ends
• Transaction records and proof of funds for regulatory inspections
• AML risk assessments and internal training records
6. AML Training for Staff
All employees must:
• Complete AML training annually
• Recognise red flags and suspicious activity
• Follow internal reporting procedures
A Money Laundering Reporting Officer (MLRO) oversees compliance and ensures staff understand their obligations.
7. Non-Compliance & Penalties
Failure to comply with AML regulations can result in:
• Fines & penalties imposed by HMRC
• Criminal prosecution for individuals and the business
• Loss of professional licenses
8. Contact & Reporting
For AML compliance inquiries, contact our Money Laundering Reporting Officer (MLRO): hello@eyup-move.me | 01484 972054 | Martin House, 2 Martin Street, Brighouse, HD6 1DA.
At any stage of the transaction, should we feel there are reasonable grounds to suspect money laundering or terrorist financing, whether it in relation to information received or any other aspect of the sale or let, we are legally obliged to report and submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) at nationalcrimeagency.gov.uk
APPENDIX A
Our agency requires one document from List A and one from List B from all customers.
Where applicable, please ensure that documents include full name(s), service addresses and account numbers and are not provided in the form of general correspondence.
List A – Identity Document
• Current signed Passport
• Current UK/EU photo Driving Licence
• Resident Permit issued to EU nationals by the Home Office
• Inland Revenue Tax notification
• State Pension or Benefits book/notification letter
List B – Proof of Address
• Current UK/EU photo Driving License, if not used in A
• Council tax bill
• Benefits entitlement letter
• Local authority rent card
• Tenancy agreement
• Bank statement
• Utility bill from the last three months
• Telephone bill excluding mobile pay as you
• Home or motor insurance certificate
• NHS medical card or letter from GP confirming registration
• Police registration certificate
List C – Proof of Ownership
• Most recent mortgage statement
• Home or motor insurance certificate
• Solicitors letter confirming house purchase/deeds/land registration
List C – Probate
If you are acting as a representative of an estate, we require the following:
• Grant of Probate (if a will was left)
• Letter of Administration (if no will left)
• Individual identity evidence from List A & B for the personal representative, either executor or administrator
Limited Company
If you are acting as a representative of a UK Company, we will also require the following:
• Certificate of Incorporation
• Articles of Association
• Memorandum of Association
• Latest Annual Return or Confirmation Statement, with details of current company officers
• If offshore, nominee director declaration and a general Power of Attorney
• Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares/ or voting rights in the company
Offshore Company
If you are acting as a representative of an Offshore Company, we will also require the following:
• Certificate of Incorporation
• Articles of Association, Memorandum of Association, Latest Annual Return with details of current company officers, Share Certificate(s) showing the Ultimate Beneficial Owner OR
• Certificate of Incumbency
• If the shares are owned by another company, repeat steps above for the holding company
• Nominee director declaration and/or general Power of Attorney (if applicable)
• Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares/ or voting rights in the company
Trust
If you are acting as a Representative of a Trust we require the following:
• Trust deed
• List of trustees
• List of beneficiaries
• Individual identity evidence from List A & B for all individuals with a vest interest in 25% or more of the capital and/or those who exercise control over the trust
