Money Laundering Checks
Righthaus properties are subject to the Money Laundering Regulations 2017. This means that we have to obtain and hold identification and proof of address for all clients. Additionally, we are also required to establish whether there are any beneficial owners on whose behalf the transaction or activity is taking place, hence, we would request you to identify anyone who you would consider to be a beneficial owner. Where appropriate, the source or destination of funds may also be requested. Without this information we will be unable to proceed with any work on your behalf.
Righthaus properties has stringent internal controls and monitoring systems in place to satisfy themselves that their clients are not involved with criminal or fraudulent activity.
Identity Documents
Customer due diligence for Righthaus properties involves establishing from the outset:
The client’s identity
The client’s proof of address
Righthaus properties obtain this information by requesting clients provide certain documentation. We require sight of all original or certified documents and may arrange for a representative to meet you in person so that photographs / photocopies of documents can be carried out for our records. Once Righthaus properties are in receipt of all necessary documents these will be analysed in more detail using fraud detection software (if required).
Below is a list of acceptable identity documents. Subject to your individual circumstances, Righthaus properties may liaise with you for further/other documentation.
LIST A – IDENTITY DOCUMENT
Current signed passport
Valid UK driving licence
EEA member state identity card
LIST B – PROOF OF ADDRESS
UK/EU/EEA Drivers Licence (if UK Drivers Licence not used as ID) – Must be valid, not expired. Photo only. Full or provisional.
Bank, Building Society or Credit Union Statement – Dated with 3 months. Must include account number and show recent activity. No general correspondence.
Credit Card Statement – Dated within 3 months. Must include account number and show recent activity. No general correspondence.
UK, EU, EEA Mortgage statement – Dated within 12 months. Must show account number. No general correspondence.
Utility Bill – Dated within 6 months E.g., Gas, electricity, water. Must show address for service and/or account number. No general correspondence.
Telephone Bill – Dated within 6 months E.g., Landline or mobile pay monthly (excluding pay as you go). Must show address for service and/or account number. No general correspondence.
Council Tax – Dated within 12 months. Must show address for service and/or account number. No general correspondence.
Tenancy Agreement – Dated with 12 months. Must state full name and full property address. Issued by local council, housing association, solicitor or reputable letting agent.
Benefits Entitlement Letter – Dated within 12 months. Issued by DWP or Jobcentre plus. Must confirm benefit payable at time of issue. E.g., Pension, disability, single parent, housing etc.
HMRC Tax Notification – Dated with 6 months. Must state national insurance number and tax calculation. No general correspondence.
Home or Motor Insurance Certificate – Dated within 12 months. Must state insured address or registered address for vehicle and policy number. No general correspondence.
UK solicitors letter confirming house purchase/land registration – Dated with 3 months. Must state full name of new proprietor and full property address.
NHS Medical Card or letter from GP confirming registration – Dated within 3 months. Must state individual’s date of birth and NHS number. No general correspondence.
Official confirmation of Electoral Register entry or official poll card – Dated within 12 months. Must state full name and full address. No general correspondence.
Police Registration Certificate – Dated within 12 months. Must state the full residential address of the individual.
Righthaus properties also require vendors to be photographed and provide their signatures in the presence of our Representative. Clients / property owners are to advise us if they have changed their name in the last year to assist Righthaus properties with their check for name changes.
Probate
If you are acting as a Representative of an Estate, we require the following:
Grant of Probate (if a will was left)
Letter of administration (if no will left)
Individual identity evidence from List A & B for the Personal Representative, either executor or administrator
Limited company
If you are acting as a Representative of a UK Company, we will also require the following:
Certificate of Incorporation
Articles of Association
Memorandum of Association
Latest Annual Return or Confirmation Statement, with details of current company officers
If offshore, nominee director declaration and a general power of attorney
Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company.
If you are acting as a Representative of an Offshore Company, we will also require the following:
Certificate of Incorporation
Articles of Association, Memorandum of Association, Latest Annual Return with details of current company officers, Share Certificate(s) showing the Ultimate Beneficial Owner OR
Certificate of Incumbency
If the shares are owned by another company, repeat steps above for the holding company.
Nominee director declaration and/or general Power of Attorney (if applicable)
Individual identity evidence from List A and B for all individuals or entities with 25% or more of the shares or voting rights in the company.
Trust
If you are acting as a Representative of a Trust, we require the following:
Trust deed
List of trustees
List of beneficiaries
Individual Identity evidence from List A & B for all individuals with a vest interest in 25% or more of the capital and/or those who exercise control over the Trust.
Further due diligence
If Righthaus properties has any doubts at all about a client’s identity, we won’t continue to deal with you until we are completely satisfied of your identity and if the situation presents itself, we will report the individual(s) to the appropriate regulatory authorities.
Righthaus properties as regulated property buyers will apply further due diligence measures on their clients when:
A transaction takes places / due to take place over 15,000 GBP
There is a suspicion of money laundering.
There are doubts / suspicions about a client’s identification.
If circumstances change with an existing client
If the client is not physically present when identification checks take place
When a business relationship takes place with a politically exposed person
There is a high risk of money laundering.
Notice to property sellers.
Righthaus properties is a member of the UKALA (UK Association of Letting Agents) and The Property Ombudsman. We are committed to preventing fraud in the property industry. The estate agency industry unfortunately has become targeted by fraudulent sellers of late and it is for this reason why Righthaus properties are cautious and vigorous at the same time in establishing the identities of their clients.
Righthaus properties is committed to combating Money Laundering and the prevention of fraud and identity theft. The main legislation governing money laundering is the Proceeds of Crime Act 2002, and abiding to this legislation, Righthaus Properties undertake physical and documentary checks to prove homeowners’ identity and proof of residence. The ultimate reason for doing this is to protect the Righthaus properties brand, business and the general public.
If clients of Righthaus Properties decide not to choose a lawyer recommended by us, Righthaus will subsequently then have to undertake due diligence checks on your legal representative. If Righthaus properties suspect any sign of fraudulent activity there will be no hesitation to report the offence to our Money Laundering Regulatory Officer (MLRO) and in turn the National Crime Agency.
A warning to potential fraudsters
Righthaus properties has a reputation for selling properties quickly and for this reason we can be targeted by fraudsters who attempt to carry out identity theft. Identity theft is generally where the property owner gives the impression that they are the property owners and then sell the property without the knowledge of the true owner.
Righthaus properties continually train their employees on money laundering and counter fraud measures and have a good working relationship with the relevant authorities in this field. In addition
to the documents we will obtain from clients, Righthaus properties will also undertake further authentication checks in addition to the ones highlighted above.
Righthaus properties has a relationship with the National Crime Agency and we regularly report our suspicions so that the business and the general public are protected at all times. We often report suspicions in confidence to the National Crime Agency and can still act to proceed with a potentially fraudulent purchase with a view to catching fraudsters with the appropriate authorities.
With a view to being transparent, all telephone calls are recorded for training and monitoring purposes.