Regulatory Framework
Property Market Hub Ltd operates in accordance with:
- The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
- The Sanctions and Anti-Money Laundering Act 2018
As a property agency, we are required to implement effective measures to prevent money laundering, terrorist financing and financial crime.
Our Responsibilities
We are legally required to:
- identify and verify all customers before entering into a business relationship
- assess and manage financial crime risks
- carry out customer due diligence and enhanced due diligence where required
- monitor business relationships on an ongoing basis
- maintain records of checks and decisions
- report suspicious activity
these obligations apply to buyers, sellers, landlords and tenants where applicable
Risk-Based Approach
we adopt a risk-based approach to compliance
this means we:
- assess the level of risk presented by each client and transaction
- apply appropriate levels of due diligence
- carry out enhanced checks for higher-risk situations
- maintain a documented firm-wide risk assessment
Customer Due Diligence (CDD)
before entering into a business relationship, we must:
- verify identity and proof of address
- identify and verify beneficial owners
- confirm whether a client is acting on behalf of another party
- understand the purpose and nature of the transaction
these checks are mandatory and cannot be waived
Enhanced Due Diligence (EDD)
enhanced due diligence is applied where higher risk is identified, including:
- politically exposed persons (peps)
- overseas clients or high-risk jurisdictions
- complex ownership structures
- unusual or high-value transactions
- unclear or unexplained source of funds
this may include additional verification of identity, source of funds and source of wealth
Identity Verification Requirements
all customers must provide:
- one document from list A (identity)
- one document from list B (proof of address)
- documents must be original or certified copies
list A – identity
- current signed passport
- valid UK driving licence
- EEA identity card
list B – proof of address
examples include:
- bank or credit card statement (within 3 months)
- utility bill (within 6 months)
- council tax bill (within 12 months)
- HMRC letter (within 6 months)
- tenancy agreement (within 12 months)
we may request additional documents where required
Source of Funds and Wealth
where required, we must verify:
- source of funds
- source of wealth
failure to provide satisfactory evidence may prevent a transaction from proceeding
Financial Sanctions Compliance
we comply with the Sanctions and Anti-Money Laundering Act 2018
we are required to:
- screen clients against the UK financial sanctions list
- ensure no services or funds are provided to designated persons
- report any confirmed or suspected matches to the relevant authority
failure to comply may result in criminal liability
Politically Exposed Persons (PEPs)
a politically exposed person (pep) is an individual who holds or has held a prominent public function, including their family members and close associates
where a client is identified as a pep, we will:
- apply enhanced due diligence
- verify source of funds and wealth
- carry out enhanced ongoing monitoring
Ongoing Monitoring
we monitor business relationships and transactions to:
- identify changes in risk
- update due diligence where necessary
- ensure ongoing compliance
aml compliance is continuous and not a one-off process
Record Keeping
we maintain records of:
- identity verification documents
- risk assessments
- due diligence checks
- transaction information
records are retained in accordance with legal requirements and may be provided to regulators upon request
Reporting Obligations
where we know or suspect money laundering or financial crime, we are required to:
- escalate internally
- submit a suspicious activity report
failure to report may constitute a criminal offence
Data Protection
all personal data collected for aml purposes is handled in accordance with our Privacy and Cookies Policy, which sets out how personal information is processed, stored and protected
Important Information
- we reserve the right to request additional documentation
- failure to provide required information may delay or prevent a transaction
- we may refuse to act where compliance requirements are not met
Compliance Position
this policy ensures:
- compliance with UK aml and sanctions legislation
- alignment with hmrc supervision expectations
- protection against fraud and financial crime
- a consistent and audit-ready framework
final positioning
this version is now:
- clean and non-duplicative with your privacy policy
- fully aligned with uk legislation
- suitable for website, onboarding and audit
- commercially strong and regulator ready
