At the end of 2019, we were approached by a UK registered family run Estate Agency based within Milton Keynes. The nature of an estate agent’s work makes it a high-risk business in relation to money laundering. To prevent any of their services being used (or potentially used) for any money laundering activity, as well as any of their staff being exposed to money laundering, they wished to put in place an anti-money laundering policy and also a process for their staff to follow and a risk assessment.
Our client knew that as of January 2020 there was going to be changes made to the regulations and wanted us to put together these documents for him ensuring his staff were protected.
Our job was to make sure our client was able to meet his legal and regulatory requirements in a way which is appropriate to the high-risk nature of the business, by taking reasonable steps to minimise the likelihood of money laundering occurring.
All employees must be familiar with their legal responsibilities so making an easy to follow questionnaire and risk assessment took away some of the pressure.
For this Client we put together a Anti-Money Laundering Policy, a Risk Assessment for each Client and a Checklist for staff to follow in order to ensure all checks had been conducted and records kept for the designate period of time. The responsibility of storing and recording files sits with the Managing Director in this case. We ensured he understood his obligations in terms of protecting and backing up records stored electronically.