Last Updated: 11 May 2025
At Deals at 234, we are committed to maintaining the highest standards of compliance with Anti-Money Laundering (AML) regulations. To ensure the integrity of our operations and compliance with the Anti Money Laundering, Terrorist Financing, and Transfer of Funds Regulations 2017, we adhere to strict AML policies and procedures, including but not limited to:
1. Risk Assessment
1.1. Client Risk Profiling
- We will categorise clients into low, medium, and high-risk based on factors such as their source of funds, transaction history, and background.
- High-risk clients may include those with limited financial history, unusual transaction patterns, or clients residing in high-risk jurisdictions.
1.2. Property Risk Assessment
- We will assess the risk associated with the properties we source by checking for any adverse legal or financial history, liens, or title disputes.
- Properties located in high-risk areas or those associated with high-risk individuals will receive special attention and be subject to Enhanced Due Diligence (EDD).
1.3. Transaction Risk Assessment
We will analyse the risk associated with specific transactions, such as unusually large cash payments, complex ownership structures, or frequent and substantial property flipping.
1.4. Employee/Vendor Risk Assessment
Our employees and vendors will be vetted and monitored to prevent any potential collusion or involvement in money laundering activities.
2. Anti-Money Laundering Procedures
2.1. Client Due Diligence (CDD)
- We will perform CDD on all clients before conducting any property deals. This includes identifying and verifying the identity of clients using reliable documents, data, or information sources.
- For individuals, this will typically involve obtaining a valid government-issued photo ID, proof of address (dated within 3 months), and any other necessary documents.
- For legal entities, we will gather information regarding the company’s registration details, directors, and beneficial ownership information, etc.
2.2. Enhanced Due Diligence (EDD)
- For high-risk clients identified during the risk profiling process, we will conduct EDD to gain a deeper understanding of the client’s financial background and the purpose of the transactions. All Politically Exposed Persons (PEPs) and clients from high-risk jurisdictions will automatically be subject to EDD.
- EDD may involve obtaining additional documents (for example audited accounts), conducting additional background/financial checks, and seeking third-party references.
2.3. Monitoring and Reporting
- The Company will continuously monitor transactions for unusual or suspicious patterns indicative of potential money laundering activities.
- If any suspicious transactions are identified, we will promptly report them to the relevant authorities.
2.4 Staff Training
- All employees are aware of their responsibilities regarding AML compliance and are required to report any concerns or suspicions to the Money Laundering Reporting Officer (MLRO).
- All employees will undergo regular AML refresher training to ensure they are aware of the latest AML regulations, risks, and procedures. They will also be educated on recognising and handling potential money laundering red flags.
2.5. Record-Keeping
- We will maintain comprehensive records of all client’s due diligence and transaction-related information. All information held by The Company on any client will be held for 60 months (5 years).
- These records will be securely stored for the prescribed period above as mandated by AML regulations.
3. How We Run Background Checks
3.1. Public Records Search
We will access publicly available records to verify the identity of the customer and gather information about their financial history, legal disputes, and any criminal records. Public records can include property ownership records, court records, bankruptcy filings, and tax liens.
3.2. Credit Checks
We will obtain the customer’s consent to perform a credit check, which can provide insights into their financial history, creditworthiness, and any outstanding debts or defaults.
3.3. Reference Checks
We will request references from the customer to validate their identity and financial background. These references can be personal or professional, such as previous landlords, employers, or business partners.
3.4. Company Registration Checks
For customers who are legal entities (e.g., companies or trusts), we will verify their registration details, beneficial ownership information, and any relevant corporate filings.
3.5. Identity Verification Services
We may utilise third-party identity verification services that can help authenticate the customer’s identity using various data sources and document verification.
3.6. Real Estate Title Search
We conduct a title search on the properties being sourced to confirm ownership, identify any liens or encumbrances, and check for any previous transactions associated with the property.
3.7. Watchlists and Sanctions Checks
We screen customers and related parties against government watchlists, sanctions lists, and politically exposed persons (PEP) databases to ensure they are not involved in any illegal or suspicious activities.
3.8. Financial Institution Database Searches
If the customer’s transactions involve financial institutions, we may request a transaction history from these institutions to monitor for any suspicious patterns or large cash transactions.
3.9. Research
We conduct online research to gather additional information about the customer or property. This may include checking social media profiles, online reviews, and news articles. Additionally, we will also consider engaging with professional background check providers or AML compliance firms that specialise in conducting thorough due diligence and background checks. These experts can ensure that our company follows best practices and adheres to AML regulations while mitigating potential risks associated with money laundering activities.
4.0 Updates to This Policy
We may update this policy occasionally to reflect changes in legal requirements or business practices. The most recent version will always be available on our website.
5.0 Contact Us
If you have any questions or concerns about this policy, please email us at: info@dealsat234.com.