Harrods Estates is deeply committed to maintaining robust controls aimed at countering the activities of money laundering and the financing of terrorism. This commitment aligns with the requirements stipulated in Statutory Instrument No.692, the Financial Services, The Money Laundering, Terrorist Financing and Transfer of Funds (information on the Payer) Regulations 2017.

For a comprehensive understanding of these regulations, please refer to the complete version available here.

Harrods Estates is duly registered with HMRC for the purpose of anti-money laundering supervision, operating in full accordance with the provisions of the Money Laundering Regulations 2017. Our approach revolves around the implementation of risk-sensitive policies and procedures designed to proactively identify and prevent instances of money laundering and terrorist financing. Operating under a risk-based framework entails a thorough assessment of the potential for customers to engage in money laundering activities within our business.

While we begin with the premise that the majority of our customers have no intention of money laundering, we have identified specific criteria that could indicate an elevated risk, such as transactions lacking face-to-face interactions for identity verification.

When relying on document-based customer identity verification, we require a government-issued document containing the customer's full name and photograph, along with either the date of birth or residential address. This includes valid passports, photo card driving licenses, national identity cards, firearms certificates, and identity cards issued by the Electoral Office for Northern Ireland. In instances where such documents are unavailable, or the customer's risk assessment does not align, we request a government-issued document without a photo, alongside secondary proof of address.

For non-private individual customers, including corporate entities and private companies, we gather pertinent information such as company registration numbers, registered addresses, and evidence of authorized individuals' roles. This extends to all shareholders holding a stake of 25% or more in the business.

Our policy mandates a comprehensive identification process and ongoing monitoring for all stakeholders—landlords, tenants, vendors, purchasers and introducers. A minimum of one form of photographic ID is required, coupled with evidence of residence like a utility bill dated within the last three months. Alternatively, we conduct authorized online money laundering checks through approved suppliers. In cases where face-to-face meetings are not feasible, we adopt enhanced due diligence measures, encompassing additional information and certified document verification.

Harrods Estates places significant emphasis on ongoing staff training to ensure a deep understanding of anti-money laundering legislation, a facet that is also integral to the induction process for all new team members.

Our dedicated Money Laundering Reporting Officer is responsible for receiving internal reports and, when necessary, forwarding them to the National Crime Agency (NCA). By adhering to meticulous "Due Diligence" identification protocols on every occasion, we mitigate the possibility of our business being exploited for money laundering or terrorism financing purposes.

Harrods Estates enforces a stringent policy concerning Suspicious Activity Reporting. Staff members and nominated officers are encouraged to report any reasonable suspicion of money laundering or terrorist financing. Such reports are directed to our designated Money Laundering Reporting Officer, who, upon confirmation of grounds for suspicion, proceeds to file a Suspicious Activity Report (SAR) with the NCA.

Indicators of suspicious activity encompass a range of scenarios, including reluctance to provide identity details, attempts to conceal identity through intermediaries, and transactions with no apparent legitimate basis. Regular customers also draw attention when third-party payments appear unconnected or when funds' sources remain undisclosed.

Strict record-keeping practices are paramount. Harrods Estates mandates the retention of records for a period of seven years, including evidence of customer identity and supporting documentation related to customer relationships and transactions. These records not only affirm our adherence to regulations but also contribute to any potential investigative processes.

Harrods Estates is steadfast in its commitment to upholding the highest standards of anti-money laundering practices, fostering transparency, and safeguarding the integrity of our operations.

Anti Money Laundering Policy