AML | Douglas Estates & Properties

Anti-Money Laundering (AML) Statement

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1. Our Commitment

Douglas Estates and Properties Limited is fully committed to preventing money laundering, terrorist financing, fraud, bribery, corruption and all forms of financial crime.

The UK property market has an important role in protecting the integrity of the financial system, and we recognise our legal and professional responsibility to ensure that our services are never knowingly used to facilitate criminal activity.

We are committed to maintaining the highest standards of regulatory compliance, ethical conduct and professional integrity. Every property transaction handled by Douglas Estates and Properties is approached with appropriate diligence, careful scrutiny and a commitment to acting in accordance with the law.

Anti-money laundering compliance forms an integral part of our day-to-day operations and is embedded throughout our policies, procedures and staff training.

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2. Legislative Framework

Our anti-money laundering procedures are designed to comply with all applicable legislation and regulatory requirements, including, where relevant:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended).

• The Proceeds of Crime Act 2002.

• The Terrorism Act 2000.

• The Sanctions and Anti-Money Laundering Act 2018.

• The Criminal Finances Act 2017.

• The Economic Crime (Transparency and Enforcement) Act 2022.

• The Economic Crime and Corporate Transparency Act 2023.

• Applicable HM Treasury Financial Sanctions guidance.

• Guidance issued by HM Revenue & Customs.

• Guidance issued by the National Crime Agency.

• Relevant UK legislation concerning fraud, bribery and corruption.

We regularly review our compliance framework to reflect legislative changes and evolving best practice.

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3. Our Compliance Culture

We believe effective compliance extends beyond legal obligations.

Our objective is to foster a culture in which integrity, transparency and professional judgement underpin every transaction.

All members of our business are expected to:

• act honestly;

• exercise professional scepticism;

• identify unusual activity;

• report concerns promptly;

• maintain confidentiality;

• comply with internal procedures;

• support regulatory compliance at every stage of a transaction.

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4. Customer Due Diligence (CDD)

Before establishing a business relationship, or where legally required during the course of a transaction, we undertake appropriate Customer Due Diligence.

This may include verification of:

• full legal name;

• residential address;

• date of birth;

• photographic identification;

• proof of address;

• ownership interests;

• beneficial ownership;

• corporate structure;

• authority to act;

• legal capacity.

The level of verification undertaken will reflect the nature and risk profile of the transaction.

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5. Identity Verification

Identity verification may be completed using one or more methods, including:

• passport;

• UK driving licence;

• biometric residence permit;

• government-issued identification;

• utility bills;

• bank statements;

• council tax documentation;

• electronic identity verification systems;

• trusted independent data sources.

Where necessary, additional evidence may be requested.

Failure to provide satisfactory identification may prevent us from acting.

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6. Enhanced Due Diligence

Where legislation or our risk assessment requires, Enhanced Due Diligence may be undertaken.

Circumstances may include, but are not limited to:

• higher-risk transactions;

• unusually complex ownership structures;

• overseas entities;

• politically exposed persons (PEPs);

• sanctions-related concerns;

• unusually high-value transactions;

• transactions involving high-risk jurisdictions;

• unusual payment arrangements;

• complex trust structures;

• transactions inconsistent with known circumstances.

Enhanced Due Diligence may involve obtaining additional documentation, verifying further information and conducting additional enquiries before proceeding.

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7. Source of Funds and Source of Wealth

Where appropriate, we may request information regarding:

• source of funds;

• source of wealth;

• purchase financing;

• inheritance;

• investments;

• business income;

• employment income;

• gifts;

• asset disposals.

Supporting documentation may be requested where necessary.

Failure to provide satisfactory evidence may prevent us from proceeding.

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8. Beneficial Ownership

Where we act for companies, partnerships, trusts or other legal entities, we may be required to identify and verify individuals exercising ownership or control.

This may include:

• directors;

• shareholders;

• trustees;

• beneficiaries;

• partners;

• ultimate beneficial owners.

Additional documentation may be requested where appropriate.

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9. Politically Exposed Persons (PEPs)

Where legally required, we undertake screening to determine whether a client or connected person is a Politically Exposed Person or is associated with a PEP.

Being identified as a PEP does not automatically prevent us from acting.

However, enhanced due diligence and ongoing monitoring may be required.

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10. Financial Sanctions Screening

We may carry out screening against applicable UK financial sanctions lists.

Where required by law, transactions may be delayed, restricted or declined pending the outcome of sanctions checks.

Douglas Estates and Properties will comply fully with all applicable sanctions legislation.

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11. Risk-Based Approach

Our compliance framework adopts a risk-based approach.

Factors considered may include:

• client profile;

• transaction value;

• transaction complexity;

• geographic location;

• ownership structure;

• payment methods;

• source of funds;

• transaction purpose;

• beneficial ownership;

• unusual behaviour.

Higher-risk matters receive increased scrutiny.

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12. Ongoing Monitoring

Compliance does not conclude once identity has been verified.

Throughout the course of a business relationship we may continue to monitor:

• transaction activity;

• changes in ownership;

• changes in instructions;

• unusual payment requests;

• inconsistencies;

• emerging risk indicators.

Where appropriate, updated documentation may be requested.

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13. Record Keeping

Douglas Estates and Properties maintains appropriate records of customer due diligence and compliance activity in accordance with applicable legislation.

Records may include:

• identity verification;

• risk assessments;

• due diligence documentation;

• transaction records;

• compliance decisions;

• correspondence.

Records are retained securely and only for as long as required by law.

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14. Confidentiality

Information obtained for anti-money laundering purposes is treated confidentially.

It is only shared:

• where legally required;

• with authorised regulatory bodies;

• with law enforcement agencies;

• where disclosure is permitted by law.

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15. Suspicious Activity

Where circumstances give rise to reasonable grounds for suspicion, Douglas Estates and Properties will comply fully with its legal reporting obligations.

We reserve the right to suspend, delay or terminate services where required by law or where appropriate compliance concerns arise.

In accordance with applicable legislation, we may be prohibited from informing individuals that a report has been made to the relevant authorities.

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16. Refusal of Instructions

We reserve the right to decline to act where:

• satisfactory identification cannot be obtained;

• due diligence requirements are not met;

• false information is suspected;

• documentation appears unreliable;

• compliance concerns remain unresolved;

• continuing to act would place the business in breach of legal obligations.

Such decisions are made to protect both our clients and the integrity of the property market.

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17. Staff Training

Our personnel receive appropriate anti-money laundering awareness and compliance training.

Training may include:

• legislative requirements;

• identifying suspicious activity;

• customer due diligence;

• enhanced due diligence;

• sanctions awareness;

• fraud prevention;

• reporting obligations;

• data protection;

• record keeping;

• ethical responsibilities.

Training is reviewed periodically to reflect changes in legislation and emerging financial crime risks.

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18. Internal Governance

Compliance forms part of our wider corporate governance framework.

Our internal arrangements include:

• documented compliance procedures;

• periodic policy reviews;

• risk assessments;

• secure record management;

• management oversight;

• continual improvement.

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19. Working With Professional Advisers

Where appropriate and legally permissible, we may work alongside:

• solicitors;

• licensed conveyancers;

• mortgage advisers;

• surveyors;

• accountants;

• financial institutions;

• compliance professionals.

This assists in ensuring transactions proceed lawfully and transparently.

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20. Our Commitment to Ethical Practice

Douglas Estates and Properties is committed to conducting business honestly, transparently and responsibly.

We do not knowingly participate in transactions involving criminal property, tax evasion, terrorist financing, sanctions breaches or any other unlawful activity.

We expect the same high standards from those with whom we conduct business.

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21. Continuous Review

Financial crime continues to evolve.

Accordingly, we regularly review our compliance framework, policies and procedures to reflect:

• legislative developments;

• regulatory guidance;

• industry best practice;

• technological developments;

• emerging financial crime risks.

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22. Contact

Questions regarding this Anti-Money Laundering Statement may be directed to:

Douglas Estates and Properties Limited

Unit 3

Wilden Lane

Wilden Industrial Estate

Stourport-on-Severn

Worcestershire

DY13 9JY

Email: enquiries@douglasestatesandproperties.com

Telephone: 01299 575766