ANTI MONEY LAUNDERING POLICY
Churcher Estates is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in accordance with the Money Laundering Regulations 2017 and is registered and supervised by HM Revenue & Customs for compliance.
HOW WE MANAGE RISK
The Money Laundering Regulations require us to risk assess our business relationships to understand our customers and identify behaviour and circumstances that may indicate a higher risk of money laundering and terrorist financing activities. Churcher Estates has undertaken and documented a thorough risk assessment and we have subsequently implemented the appropriate policies and procedures required to minimise this risk.
Churcher Estates is committed to staff training in anti-money laundering legislation to ensure they are aware of the risks of money laundering and terrorist financing, the relevant legislation and their responsibilities under that legislation and that they are fully trained in the firm’s procedures and in how to identify and deal with potential money laundering or terrorist financing activities. This training is delivered to new employees as part of the on-boarding process and via ongoing group training sessions and communications thereafter.
CUSTOMER DUE DILIGENCE (CDD) MEASURES
Adherence to the approved “Due Diligence” identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism. For this purpose, we use a third-party electronic verification solution to verify the identity of an individual. In order to minimise the risk of the business unknowingly transacting with PEP or sanctioned individuals and/or facilitating money laundering/terrorist activities, we have taken the decision to apply Enhanced Due Diligence (EDD) in all cases, as part of our standard electronic verification process. Proof of Ownership (where relevant) is also carried out electronically, as part of our standard CDD process. Where the electronic verification process is unsuccessful or inconclusive, we will collect documents, as stipulated within the current regulatory guidance.
SUSPICIOUS ACTIVITY REPORTING
The staff member dealing with the individual/transaction will notify the Money Laundering Reporting Officer (MLRO) or Deputy MLRO if they have reason to suspect that a person may be engaged in money laundering and/or terrorist financing. The MLRO and/or Deputy MLRO will review the information to hand and make a final judgement as to whether or not to submit a Suspicious Activity Report (SAR) to the National Crime Agency. Any decision made to submit a SAR will be confidential and not shared with the subject or any member of staff. Contact details for the appointed MLRO and Deputy MLRO are provided below.
In accordance with current legislation records of all Customer Due Diligence will be retained for at least five years from the end of the business relationship or five years from the date the transaction was completed. The purpose of keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations. The personal data we are obliged to collect under these regulations is necessary in order to exercise a public function that is in the public interest and we cannot lawfully delete it, even if requested under GDPR legislation until this period has lapsed. Copies of all personal data and any documents procured for the purposes of identity verification will be stored electronically.
Money Laundering Reporting Officer:
Liverpool Rd S, Burscough, Ormskirk L40 7SU
This policy was revised in March 2022 and supersedes any earlier version.