1. Purpose & scope

This policy sets out how [the firm] verifies the identity, background and legitimacy of its clients in order to prevent money laundering, terrorist financing and other financial crime. It applies to all staff, contractors and agents, and to all client relationships and occasional transactions the firm undertakes. It should be read alongside any applicable anti-money laundering regulations enforced by [the relevant supervisor].

2. Roles & responsibilities

[MLRO name] is appointed as the firm's Money Laundering Reporting Officer (MLRO) and is responsible for oversight of this policy, receipt of internal suspicious activity reports, and onward reporting to the relevant authority.

• All staff must complete KYC checks before establishing a business relationship.
• All staff must escalate suspicions internally to the MLRO without delay.
• Senior management is accountable for the firm-wide risk assessment and controls.

3. Client types in scope

The firm applies this policy to the following categories of client:

• Individuals. Natural persons purchasing, selling or renting in a personal capacity.
• Companies. UK and overseas corporate entities, including their directors and beneficial owners.
• Overseas buyers. Clients resident or based outside the firm's home jurisdiction.

4. Identification & verification

Before establishing a business relationship, the firm verifies each client's identity using reliable, independent sources. The following methods are approved for use:

• Passport. Valid, in-date passport with machine-readable zone verified.
• Utility bill. Recent (within 3 months) utility or bank statement as proof of address.
• Electronic ID check. Digital identity verification against independent data sources.

For corporate clients and trusts the firm additionally identifies beneficial owners holding 25% or more of the entity and verifies their identity using the same methods.

5. Risk-based approach

The firm operates a medium risk appetite. Each client is risk-rated at onboarding using factors including jurisdiction, client type, source of funds, transaction size and political exposure. Enhanced Due Diligence (EDD) is applied where:

• The transaction value is $100,000 or more.
• The client is a Politically Exposed Person (PEP) or a close associate.
• The client is based in, or funds originate from, a high-risk jurisdiction.
• The client structure is unusually complex or obscures beneficial ownership.
• The client appears on any applicable sanctions list.

7. Ongoing monitoring

Client relationships are reviewed on a risk-sensitive basis: high-risk clients at least annually, standard-risk clients at least every three years, and whenever a material change in circumstances is identified. Transactions are monitored for consistency with the firm's knowledge of the client and their source of funds.

8. Suspicious activity reporting

Any member of staff who knows or suspects that a client is engaged in money laundering or terrorist financing must submit an internal report to [MLRO name] immediately and must not tip off the client. The MLRO will consider the report and, where appropriate, submit a Suspicious Activity Report to the relevant authority.

9. Record keeping

Identification evidence, risk assessments, transaction records and internal reports are retained for 5 years from the end of the business relationship or completion of the transaction, whichever is later.

10. Training & review

All relevant staff receive AML training at induction and at least annually thereafter. This policy is reviewed at least annually by the MLRO and senior management, and updated whenever the firm's risk profile, services or applicable regulations materially change.