Anti Money Laundering Policy

Trading with Prosperty Group Limited is subject to these Terms and Conditions. References to “we”, “us” and “our” are references to Prosperty Group Limited incorporated and registered in England and Wales with Company Number 13131891 whose registered office is 85 Great Portland Street, First Floor, London, W1W 7LT.

The terms “you”, “your” and “investor” refer to any individual, company or business to whom we provide our services by any means including, but not limited to, email, telephone, face-to-face contact, postal correspondence or via our website https://www.prospertygroup.co.uk. 

Introduction

Prosperty Group Limited is committed to ensuring that it has adequate controls to assess the risk that the company may be used for money laundering or terrorist financing. We’ve put in place appropriate measures to manage and lessen those risks, in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Our Anti-Money Laundering (AML) Policy exists to prevent the company being used to legitimise illegally obtained funds and to assist employees if any money laundering activity is suspected. Risk assessments will be carried out within our policies and procedures to help prevent money laundering and terrorist financing occuring. This policy and our procedures will be reviewed annually to ensure they adequately reflect the risk of money laundering to the company. Our registration number is: XLML00000160366.

Money Laundering Reporting Officer (MLRO)

Our nominated Money Laundering Reporting Officer (MLRO) is Chloe Harris, whose responsibility is to receive internal reports. Our MLRO is then responsible for making a decision as to whether further due diligence is needed or a report should be made to The National Crime Agency. If it is decided that a report must be made, it is the responsibility of our MLRO to file the report with The National Crime Agency (NCA).

The Money Laundering Regulations 2007

The law requires us to follow procedures to prevent criminals from being able to use our services to launder money, or to finance terrorism. All references in this manual to money laundering include terrorist financing. If you have any questions relating to our AML policy, please contact the MLRO.

Registration

Prosperty Group Limited have completed the registration process with HMRC Anti-Money Laundering Supervision.

A copy of our proof of registration (confirmation email from HMRC) can be requested by contacting us via email: info@prospertygroup.co.uk.

Record Keeping

The company is required to maintain records (including records of client identification and their transaction details) for at least five years from the end of our business relationship with a client. Personal data received from clients is protected by data protection law. It must be used or processed only for the purposes of preventing money laundering.

1. Any evidence obtained to prove a client’s identity, address, proof of funds or source of funds, including results from any electronic checks carried out. 
2. Any supporting records relating to a client relationship or occasional transaction, such as communications etc.

Prosperty Group Limited will ensure that all personal information will be held in a secure manner and in line with guidance from the Information Commissioner’s Office (ICO). If you would like more information about how we will hold your personal data you can access a copy of our full Data Privacy Policy: 

Here is a link to our Data Privacy Policy: DataPrivacyPolicy

Training

Prosperty Group Limited ensures that all employees receive training about the law relating to money laundering, and how to recognise and deal with suspect transactions. Employees will receive updated training annually dependent on their individual job roles. We hold employee training records to monitor training needs, assess any potential shortfalls in training and the effectiveness of any training given to staff members.

Customer Due Diligence (“CDD”)

Prosperty Group Limited are required to check that our clients are who they claim. That is because crooks often try to buy and sell property using false names, nominees, companies or trusts to hide their ownership. 

As well as checking a client’s identity we need to:

• obtain information on the purpose and intended nature of the business relationship (which is often obvious), 
• assess risk (because our checks must be done on a risk-sensitive basis) and 
• monitor the business relationship for anything suspicious.

Risk Assessment

As an estate agency type business we operate in a relatively ‘high risk’ sector. Due to this we operate a ‘Two Tier’ risk assessment process to identify our clients as either ‘Low’ or ‘High’ risk. We then select the appropriate Client Identification and Due Diligence Process outlined below.

Client Identification and Due Diligence – Seller & Buyer

Prosperty Group Limited operates a risk-based approach and we identify criteria that may indicate a higher risk of money laundering. Our risk-based approach assesses the risk of client’s laundering money through our business activities and whilst we accept that the majority of our clients will not launder money, we must identify criteria that would indicate a higher risk of money laundering.

Should a face-to-face meeting not take place then our enhanced due diligence procedure will be adopted. This includes asking for additional information or evidence to establish the client’s identity and ensuring that any documents supplied are certified.

Buyer

Prosperty Group Limited will collect data relevant to the level of risk posed by any individual client, which will include manually collecting sufficient information to show: 

• The Buyer is who they say they are – gathering copies of Passports/Driving Licenses 
• The Buyer lives where they say they live – gathering copies of Utility Bills < 3 Months old 
• They have the funds to make any purchase – gathering copies of appropriate account statements 
• They can provide an audit trail to show the ‘source of their funds’ to be used for any purchase – will vary dependent on source of funds

Seller

Where Prosperty Group Limited are direct to the Seller, we will collect data relevant to the level of risk posed by any individual client, which will include manually collecting sufficient information to show: 

• The Seller is who they say they are – gathering copies of Passports/Driving Licenses 
• The Seller lives where they say they live – gathering copies of Utility Bills < 3 Months old 
• They have the legal right to sell the property or site – Land Registry Checks and/or Proof of Power of Attorney

Enhanced Due Diligence – High Risk Matters and Clients

Prosperty Group Limited carry out “enhanced due diligence” in any case where there is a high risk of money laundering. The law says that includes the following. 

• We are dealing with a person established in a high-risk country. 
• The client is a “politically exposed person” (known as a “PEP”), or a family member or known close associate of a PEP. 
• The client has provided false or stolen information. 
• A transaction is complex and unusually large. 
• There is an unusual pattern of transactions, and the transaction or transactions have no apparent economic or legal purpose. In addition you should be aware of the following risk factors which particularly apply in the context of this company.
• Cash transactions. The company’s policy is that we only accept cash from anyone up to a limit of £500 in any 28 day period. 
• Clients who use complex corporate or trust structures to own property. 
• Funds are coming from a high-risk country. • Funds being provided by someone other than the buyer or a mortgage lender.
• A property is being rapidly re-sold, in circumstances which may suggest mortgage fraud.

Suspicious Activity Reporting

WARNING: We will report all suspicious activity to The National Crime Agency (NCA)

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