Anti-Money Laundering (AML) Policies, Controls, and Procedures for Junaid Maroof Ltd Estate Agents

Introduction: Junaid Maroof Ltd is dedicated to maintaining robust measures to detect and prevent money laundering and terrorist financing in accordance with the UK Money Laundering Regulations 2017. The following policies, controls, and procedures have been designed to mitigate the risks identified in our AML risk assessment and to ensure compliance with relevant laws.

1. Customer Due Diligence (CDD)

Policy:
Customer due diligence (CDD) must be performed on all clients before any business relationship is established. The objective is to verify the identity of customers and assess the risk they may present in terms of money laundering or terrorist financing.

Procedures:

• Standard Due Diligence (SDD): Applied to all clients. Verification of identity through official documents such as passports, driving licences, and proof of address (e.g., utility bills, bank statements).
  • Obtain and retain a copy of the client’s identity and verification documents.
  • Check the client’s identity against the UK Sanctions List and PEP registers.
• Enhanced Due Diligence (EDD): Applied when higher risk is identified, such as:
  • Politically Exposed Persons (PEPs)
  • Clients from high-risk jurisdictions
  • High-value transactions
  • Non-face-to-face transactions
  • Require additional verification methods, including obtaining further details on the source of funds and the client’s wealth.
  • Seek approval from senior management for high-risk clients before proceeding.
• Ongoing Monitoring:
  • Continually monitor client transactions to ensure they align with the customer profile and expected behaviour.
  • Re-assess risk profiles as necessary if new information becomes available.

Control:

• Ensure all customer identification and due diligence records are updated and kept for 5 years following the end of the business relationship.

2. Risk-Based Approach

Policy:
Junaid Maroof Ltd adopts a risk-based approach to AML compliance, focusing resources on higher-risk areas. This ensures that customers, transactions, and services that pose the greatest threat to ML/TF are subject to increased scrutiny.

Procedures:

• Risk Assessment: Evaluate each client’s risk using criteria such as:
  • Type of customer (e.g., PEPs, corporate clients).
  • Nature of the business relationship.
  • Geographical location of the customer or property.
  • Type of transaction (e.g., high-value property sales, cash transactions).
• Client Risk Rating:
  Assign a risk rating (low, medium, or high) based on the client profile. Document all risk ratings and ensure they are reviewed periodically.
• Mitigation Measures:
  • Apply enhanced monitoring, due diligence, and approval processes for high-risk clients or transactions.
  • Avoid business relationships that present an unacceptable level of risk (e.g., transactions involving sanctioned countries).

Control:

• Keep detailed records of the risk assessment for each client and transaction, including justifications for the risk rating and the mitigation measures applied.

3. Suspicious Activity Reporting (SAR)

Policy:
Any suspicious activity or transactions that may indicate money laundering or terrorist financing must be reported to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR).

Procedures:

• Identification of Suspicious Activity:
  • Unexplained large transactions or sudden payments.
  • Transactions from clients who are unwilling or unable to provide adequate verification documents.
  • Changes in ownership structures with no clear business justification.
  • Transactions involving countries with a high risk of money laundering.
• Reporting Suspicious Activity:
  • Staff must immediately escalate any suspicions to the Nominated Officer (AML Officer).
  • The AML Officer will assess the situation and, if necessary, file a SAR with the NCA without notifying the client (known as “tipping off”).
  • SARs must be submitted within 5 working days of identifying suspicious activity.

Control:

• Maintain a secure and confidential log of all SARs submitted and related communications with the NCA.
• Ensure staff are aware of their legal obligations and the importance of reporting.

4. Geographical Risk Controls

Policy:
Increased caution will be exercised for transactions involving clients or properties located in countries with higher ML/TF risks, particularly those identified by the Financial Action Task Force (FATF) as non-cooperative jurisdictions.

Procedures:

• Sanctions and High-Risk Jurisdiction Checks:
  • Use screening tools to check if clients or transactions involve sanctioned or high-risk jurisdictions.
  • Avoid or escalate transactions involving high-risk countries to senior management for approval.
• High-Risk Jurisdiction Monitoring:
  • Review client transactions originating from high-risk countries more frequently.
  • Require additional documentation regarding the source of funds.

Control:

• Implement automated screening tools to regularly check for updates to sanction lists and high-risk jurisdictions.
• Keep records of any high-risk transactions and the additional due diligence measures taken.

5. Transaction Monitoring

Policy:
All client transactions will be monitored to detect unusual or suspicious patterns, especially those that do not match the expected profile of the client.

Procedures:

• Regular Monitoring:
  • Implement an internal monitoring system to flag unusual transactions, such as large cash deposits, sudden withdrawals, or transactions with complex ownership structures.
  • Conduct periodic reviews of ongoing client relationships, particularly for high-risk clients.
• Unusual Transactions:
  • Investigate any unusual or complex transactions to ensure they are legitimate.
  • Record all findings from investigations, even if the transaction is deemed legitimate.

Control:

• All flagged transactions will be reviewed by the AML Officer.
• Maintain records of the investigations into flagged transactions and any necessary actions taken.

6. Staff Training and Awareness

Policy:
All employees must receive training to understand their obligations under AML regulations and how to identify and report suspicious activity.

Procedures:

• AML Training:
  • Provide comprehensive AML training to all new employees within their first month.
  • Conduct regular refresher training for all staff at least once a year.
  • Ensure that training covers how to identify suspicious transactions, the importance of CDD, and how to submit SARs.
• Specialized Training for Key Staff:
  • Enhanced training for staff in higher-risk roles, such as those dealing with high-value clients, international transactions, or AML compliance.
• Records of Training:
  • Keep detailed records of all AML training provided, including dates, content, and attendees.

Control:

• The AML Officer is responsible for ensuring training is up-to-date and relevant to the latest regulations.

7. Record Keeping and Data Protection

Policy:
All records related to AML activities, including CDD, risk assessments, and SARs, must be securely maintained for a minimum of 5 years after the end of the business relationship or transaction.

Procedures:

• Document Retention:
  • Retain copies of all customer identity verification documents, transaction records, and communications.
  • Ensure all records are securely stored, either electronically or in physical form, in compliance with GDPR regulations.
• Data Security:
  • Ensure that sensitive data is protected against unauthorized access, modification, or disclosure.
  • Implement access controls to ensure only authorized personnel have access to AML-related records.

Control:

• Regular audits of record-keeping procedures to ensure compliance with legal obligations.

8. Review and Audit

Policy:
Junaid Maroof Ltd will regularly review its AML policies, controls, and procedures to ensure they remain effective and up-to-date with changes in regulation and emerging risks.

Procedures:

• Annual AML Review:
  • Conduct an annual review of the AML risk assessment and related policies, controls, and procedures.
  • Amend procedures where necessary to address emerging threats or changes in legislation.
• Internal Audits:
  • Conduct regular internal audits of client files, SARs, and due diligence processes to ensure compliance.

Control:

• Document findings from each review and ensure that any issues are addressed promptly by management.

Approved by: Junaid Maroof
Position: Director
Date: 01/08/2024