Red

Red Property Partnership Ltd Anti Money Laundering Policy

Red Property Partnership Ltd (‘Red’)

Money Laundering Policy Statement

Money Laundering Reporting Officer: Dean Worsfold

Deputy Money Laundering Reporting Officer: Rebecca Russell

“Red Property Partnership Ltd” refers to the following companies:

• Red Property Partnership Ltd

Definition of Money Laundering

Money laundering is the process through which criminals transform illegally obtained assets into seemingly legitimate ones. In the property sector, this can involve:

• Buying property assets with proceeds of crime and selling or letting them, providing criminals with a seemingly legitimate source of funds.
• Concealing criminal activity behind complex company structures involving multiple countries and bank accounts.
• Direct payment to an estate agency or lettings agent, with later reimbursement.

Related Legislation

The primary UK legislation covering anti-money laundering and counter-financing of terrorism is:

• Proceeds of Crime Act 2002
• Terrorism Act 2000
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 & Money Laundering & Terrorist Financing Amendments 2019
• Criminal Finances Act 2017
• Economic Crime (Transparency & Enforcement) Act 2022
• Terrorist Asset-Freezing Act 2010
• Anti-terrorism, Crime and Security Act 2001
• Counter-terrorism Act 2008, Schedule 7
• Bribery Act 2010

Red is committed to ensuring adequate controls to counter money laundering and terrorist financing activities, in line with The Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017 & Money Laundering & Terrorist Financing Amendments 2019. Red is registered with HMRC for anti-money laundering supervision under the Money Laundering Regulations.

Risk-Sensitive Policies and Procedures

A risk-sensitive approach is employed, where the risk of customers laundering money is assessed. While RED assumes most clients will not launder money, criteria indicating a higher risk are identified, e.g., no face-to-face meeting.

A Risk Assessment of business activities is regularly conducted to ensure compliance with Money Laundering regulations. This assessment outlines transaction types, procedural requirements, and is updated as needed.

Staff Training

Red is committed to staff training in anti-money laundering legislation, included in the induction of new staff.

Money Laundering Reporting Officer (MLRO)

The MLRO is Dean Worsfold based at The Vineyard, 36 Gloucester Avenue, NW1 7BB. The Deputy MLRO is Rebecca Russell, based at The Vineyard, 36 Gloucester Avenue, NW1 7BB.

Customer or Enhanced Due Diligence (CDD or EDD)

• All vendors, purchasers, landlords, and tenants must be identified fully with a minimum of two forms of ID.
• Enhanced due diligence is applied when no face-to-face meeting occurs.

Verification Procedures

• A Land Registry title check may be undertaken for sellers and landlords.
• An approved online money laundering ID check will be made.
• For trusts, probate, lasting power of attorney, limited companies, and LLP, specific documentation is required.

Risk Assessments

• A documented risk assessment is completed in every case.
• Regular reviews and updates of risk assessments during transactions and tenancies.

Politically Exposed Persons (PEPs) and Sanctions

• Enhanced due diligence is applied to PEPs, including checks on the source of wealth/funds.
• Sanctions checks are conducted as part of Customer Due Diligence.

Suspicious Activity Reporting

Reports are made to the MLRO if there is a suspicion of money laundering. Suspicious activities include reluctance to provide identity details, use of intermediaries, lack of evidence for the source of funds, and more.

Record Keeping

• Copies of customer identity evidence are kept for five years.
• Supporting records for customer relationships or transactions are retained for five years.

Audit of Compliance

An annual audit of compliance with Money Laundering Regulations is conducted and documented to ensure continuing compliance and staff training.

Review

This policy is reviewed annually or as needed due to changes in legislation. Last reviewed on 07/11/2023.

Questions

Any questions regarding Money Laundering Regulations and Red Property Partnership Ltd procedures should be addressed to Dean Worsfold, MLRO, at The Vineyard, 36 Gloucester Avenue, NW1 7BB or Rebecca Russell at The Vineyard, 36 Gloucester Avenue, NW1 7BB.