Outline
Interlet International Lettings & Management Co Ltd (Interlet International) is strongly committed to pro-active adherence to all Money Laundering and Terrorist Financing regulations. This means ensuring there are adequate controls, policies and procedures to maintain our compliance and protect our clients. Interlet International is regulated and supervised by HMRC, with whom we are registered for Anti Money Laundering (AML) compliance.
Assessing Risk
Under the provisions of the Money Laundering and Terrorist Financing (Amendment) Regulations 2019, we are required to perform risk assessments on our business relationships in order to identify those transactions that may entail a higher risk of proscribed activities. Interlet International maintains current copies of the UK National Risk Assessment, which defines the regulated activity of Estate Agents as HIGH risk for Money Laundering and MEDIUM risk for terrorist financing.
Interlet International undertakes regular risk assessments to identify potential new risks and adjusts procedures and policies accordingly. When procedures are changed all employees in the relevant department are notified and a training meeting is held.
Training
Interlet International is an investor in people and commits to the continuous personal development of employees. Consequently, and in line with AML obligations, all employees with AML supervisory responsibilities are regularly trained by qualified third parties. Such employees, including but not limited to executive directors and senior management, are required to lead periodic AML and Client Due Diligence (CDD) training sessions.
A record is kept of both external and internal training. Annual checks are carried out to ensure familiarity with the latest procedures and regulations. This is in addition to refresher training and legislation updates that are carried out as detailed above.
All staff performing regulated functions are required to understand the AML and CDD procedures required within their department and to know their point of contact for reporting suspicious activity for the purposes of filing a Suspicious Activity Report.
Due Diligence
As a regulated business, Interlet International must carry out a minimum standard of Client Due Diligence to mitigate the risks of Money Laundering and Terrorist Finance offences. This minimum standard is determined according to the level of risk, as determined by the responsible senior employee/director.
If any further CDD is required, for example if the AML risk is reassessed as higher than initially believed, Interlet International will conduct remedial CDD in a timely fashion.
Interlet International is required to obtain proof of identification and address for all clients. We are also required to verify the identities of any Beneficial Owners (on whose behalf a transaction takes place).
Below is a list of acceptable identity documents. We require sight of all original or certified documents. Subject to your individual circumstances, we may liaise with you for further/other documentation.
Individual Identity Documents
We require one document from List A and one document from List B.
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
Probate
If you are acting as a Representative of an Estate we require the following:
Grant of Probate (where a will was left)
Letter of administration (where no will was 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 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 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 vested interest in 25% or more of the capital and/or those who exercise control over the Trust.
CLIENT DUE DILIGENCE (CDD) MEASURES
The Individual
Adherence to the approved Client Due Diligence identification procedures on every occasion will mitigate the risks of our business being used to launder money or fund terrorism.
Proof of Ownership (where relevant) is also carried out electronically, as part of our standard CDD process.
Company or other legal structure
For clients who are not private individuals, such as corporate clients and private companies, we will take all reasonable steps to identify the Ultimate Owner and all Beneficial Owner/s and carry out Enhanced Due Diligence (EDD) on those individuals identified. We will also obtain and hold on file official/company documents, as detailed below.
Company (including a UK LLP) not listed on a regulated market such as the London Stock Exchange:
Copy of the Certificate of Incorporation
Copy of the most recent filed Audited Accounts
Details of the current company officers (Directors, Company Secretary and Shareholders)
Company (including a UK LLP) listed on a regulated market such as the London Stock Exchange:
A copy of a dated page from the website of the relevant stock exchange OR a photocopy of the listing in a reputable daily newspaper
Enhanced Due Diligence - High Risk Transactions
We must carry out Enhanced Due Diligence in any case where there is a high risk of money laundering. The law says this includes the following.
When dealing with a person established in a high-risk country.
Where the client is a “politically exposed person” (known as a PEP), or a family member or known close associate of a PEP.
The client has provided false or stolen information.
A transaction is complex and unusually large.
There is an unusual pattern of transactions and the transactions have no apparent economic or legal purpose.
Internal and External Audit
Internal compliance audits are carried out on a regular basis. As a regulated business our protected Client Monies Accounts are audited by our Chartered Accountant on a yearly basis.
Record Keeping
The law requires Interlet to keep all records of Customer Due Diligence for at least 5 years after the end of the relevant business relationship. Records of individual transactions are similarly stored for at least 5 years after the completion of the transaction.
Furthermore The Property Ombudsman, our redress scheme, requires us to store records of our interactions with clients for 7 years in the event of audit or investigation.
The ultimate purpose of long-term record keeping is the protection of the public interest and adherence to the law. This may affect the application of client rights under GDPR, including any requests under ‘the right to be forgotten’ principle. The regulatory framework providing for the retention of data (even in the face of requests to delete) is set out in Article 6 of the General Purpose Data Regulations.
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 grounds to suspect that a person may be engaged in money laundering and/or terrorist financing. The MLRO and/or Deputy MLRO will then review the information and make a final judgement as to whether to submit a Suspicious Activity Report (SAR) to the National Crime Agency. The decision to submit a SAR will be confidential and will not be shared with the subject or any member of staff. Contact details for the appointed MLRO are provided below.
Money Laundering Reporting Officer
Alexa Masterman – Associate Director
0207 361 7968
0788 941 8066
