Compliance & Tax

Our Anti-money Laundering Procedure

HOMES OR HOUSES LTD is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with Statutory Instrument No.692 Financial Services, The Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017.

HOMES OR HOUSES LTD are registered with HMRC for anti-money laundering supervision under the Money Laundering Regulations 2017. Risk sensitive policies and procedures have been established in order to anticipate and prevent money laundering and terrorist financing.

A risk sensitive or risk-based approach is where businesses assess ‘the risk’ of customers laundering money through their business. Whilst Homes or Houses Ltd take the starting point that most customers will not launder money, we do identify criteria that may indicate a higher risk. – e.g. where there is no face-to-face meeting to establish identity.

Homes or Houses Ltd is committed to staff training in anti-money laundering legislation.

Homes or Houses Ltd has a Money Laundering Reporting Officer whose responsibility is to receive internal reports and who will forward reports to National Crime Agency, if and as necessary.

It is Homes or Houses Ltd policy that all landlords, tenants, vendors and purchasers must be identified fully with a minimum of two forms of ID, evidence of identity being photographic, such as a Passport or Government issued driving license and also evidence of residential address e.g. a government issued bill, a tax return, or a utility bill dated in the last three months, (SEE BELOW).

Should a face to face meeting not take place then ‘enhanced due diligence’ procedures will be adopted by asking for additional information or evidence to establish the customer’s identity and all of the documents supplied must be certified by a Lawyer or Notary.

If the verification of the customer’s identity is done by documents this will be based on:

A government issued document with the customer’s full name and photo with either the customer’s date of birth or residential address such as:

• a valid passport
• a valid photo card driving licence
• a national identity card

Where the customer doesn’t have one of the above documents, or the customer doesn’t meet the criteria in our risk assessment, we will require independent verification by a Lawyer or a Notary before proceeding with our relationship. This independent verification must be conducted by a Government Notary.

For customers other than private individuals

For customers who are not private individuals, such as corporate customers and private companies, we will obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company from Companies House to obtain details of directors and company secretary.  From this stage the above requirements for documentation will be applied to all shareholders holding 25% or more of a business.

Suspicious Activity Reporting

A report will be made if a member of staff and the nominated officer thinks that there is a possibility, that a person is or has been engaged in money laundering or terrorist financing. The report will be made to the Homes or Houses Ltd Money Laundering Reporting Officer who, should they be satisfied that there are grounds to suspect money laundering or terrorism, will make a Suspicious Activity Report (SAR) to the National Crime Agency (NCA)

What is Suspicious Activity?

This list is by no means exhaustive but includes:

New Customers:

• Reluctance to provide details of their identity
• Customer is trying to use intermediaries to hide their identity or involvement
• There appears to be no genuine reason for the customer using the business’s services

Regular/Existing Customers:

• Money is paid by a third party who does not appear to be connected with the customer
• The customer requests payment to a third party who has no apparent connection with the customer
• A cash transaction is unusually large, and the customer will not disclose the source of funds.
• A transaction is carried out for less than market value with an unconnected person

Record Keeping

• The following records will be kept for 5 years:
• Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed.
• Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed.
• The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.