Today, I attended my first HMRC client swoop and spent the morning helping estate agent clients field questions by an HMRC team of three people on their anti-money laundering risk assessment, policies, due diligence procedures, training and record retention arrangements that I had crafted for them. Thankfully, the HMRC team Read more…
The Treasury has published a UK Government Consultation Paper on the transposition of the EU 5th Money Laundering Directive into UK law by January 2020. The Directive brings Property Letting Agents in line with Estate Agents, who will from January 2020 have to register with and comply with HMRC Rules Read more…
It was with interest that I read the RICS Professional Statement “Countering Bribery, Corruption, Money Laundering and Terrorist Financing” which was published on 1 February and will be effective from 1 September 2019. Whilst I accept that it is difficult to craft a “one size fits all document”, I have Read more…
Whilst Lawyers, Accountants and Estate Agents are respectively regulated by their own professional bodies or HMRC, all base their Anti-Money Laundering guidance on national laws, rules and regulations. All UK regulated businesses are required as part of their Anti-Money Laundering obligations to produce, and update as necessary, a general business Read more…
One has to feel sorry for Estate Agents (did I say that?), not only are they now subject to AML supervision by HMRC, but also subject to GDPR and having to register with the Information Commissioners Office. Unfortunately, leaving the EU under whichever deal, is not likely to lessen the Read more…
I have been asked by a Fund client to advise whether they should raise the bar for due diligence for Saudi investors following the horrific killing of Jamal Khashoggi in Istanbul. My gut feeling was “no” but obviously I needed to undertake some research to substantiate my view. Fortunately, two Read more…
In the UK, HM Treasury (Office of Financial Sanctions Implementation (OFSI)) are charged with enforcing the financial sanctions regimes put in place by the UN, EU and the UK. The purpose of the sanctions regimes is broadly to coerce regimes and individuals into proper standards of behaviour by denying those Read more…
Estate Agents should by now be aware of their obligations under the UK Money Laundering Regulations which came into force in June 2017, not only to undertake due diligence on their clients and customers, but also on counterparties to any relevant sale and purchase. What seems to be surprisingly unknown Read more…