1. 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.

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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

13. 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

14. 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

15. 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