Anti-Money Laundering Policy Statement for Fortress Property Solutions Ltd

(Company number 11283099)

Money Laundering Regulations 2017

Fortress Property Solutions Ltd is committed to ensuring adequate controls and measures are in place to counter money laundering and terrorist financing activities, in accordance with the Money Laundering Regulations 2017.

We are registered and supervised by HM Revenue & Customs for compliance. The purpose of our relationship with our clients is to act as an Agent for the sale and let of a property.

HOW WE MANAGE RISK

Risk Assessment

The Money Laundering Regulations require us to risk assess our business relationships in
order to understand our customers and identify behaviour and circumstances that may indicate a higher risk of money laundering and terrorist financing activities. We have undertaken and documented a thorough risk assessment and subsequently implemented the appropriate policies and procedures required to minimise this risk.

Fortress Property Solutions Ltd has undertaken and documented a thorough risk assessment and we have subsequently implemented the appropriate policies and procedures required to minimise this risk.

Training

Fortress Property Solutions Ltd is committed to Continuing Professional Development (CPD) and 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 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 on-going group training sessions and communications thereafter. All staff are obliged to read this document and return a signed, dated copy acknowledging that they have read and understood it to the Nominated Officer who will keep it on file.

Auditing

Internal compliance audits are carried out on a regular basis and all Customer Due Diligence (CDD) carried out is approved prior to the business relationship with the client or counterparty to the transaction commencing. Any remedial action and/or further training required is identified and implemented in a timely fashion.

Process

The law requires us to check the identities of our customers, or the ‘beneficial owner’ of a property, for whom we are acting as Agent. Our Nominated Officer for managing this process is our Managing Director. All of our employees are required to be familiar with this policy.

We are required to confirm our customer’s name, their photograph on an official document which confirms their identity, their residential address and date of birth. We are obliged to record that we have seen these documents. If we have doubts about a customer’s identity, we may decline to deal with them until we are sure. Any concerns should be reported to the Nominated Officer at Fortress Property Solutions Ltd.

We ask to see a government issued document – a Passport, Drivers Licence along with utility bills, bank statements and other official documents. Other sources of customer information may include the electoral register and information held by credit reference agencies such as Experian and Equifax. We intrude on our customer’s privacy to the minimum necessary to comply with the law: An identity document with photograph and a linking document with address.

We are not document experts and although we are vigilant we cannot be expected to spot expert forgeries, especially those purportedly issued in other countries, but all staff are required to review, “Guidance on examining identity documents” published on the .gov website

We are obliged to check if our customers are Politically Exposed Persons. Domestic or foreign PEP’s are individuals who are or have been entrusted with prominent public functions, for example Heads of State or of government, senior politicians, senior government, judicial or military officials, senior executives of state owned corporations, important political party officials. A family member or close associate of any of the above. As we predominantly deal in domestic properties not of the highest value and there are very few such persons it is unlikely that we will ever interact. If we do the Nominated Officer will decide a course of action.

An estate agency business enters into a business relationship with both parties to the transaction – the property seller and the property buyer. The person who is not a customer, in the commercial sense, must be treated in the same way as a customer for the purposes of the Regulations, for example, the same obligations to apply an appropriate level of customer due diligence. So we will confirm the identity of purchasers when they make a formal offer which is accepted by our client.

As a regulated business, we are subject to Anti-Money Laundering Regulations which means we must obtain and hold identification and proof of address for all customers. 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.

Below is a list of acceptable identity documents. We require sight of all original or certified documents. Subject to your individual circumstances, Fortress Property Solutions Ltd may liaise with you for further/other documentation.

Individual Identity Documents

We will require one document from List A and one recent document from List B dated within the past 3 months.

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 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 ofcurrent 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

LIST C – PROPERTY INFORMATION

• EPC Certificate
• Land Registry Certificate (You can get it from https://eservices.landregistry.gov.uk)
• Home report (Applicable to Scotland only)
• For Scotland: If you don’t have your Land Registry Certificate, you need to obtain it from yoursolicitor. Once you get the certificate, please email us to info@fortresspropertysolutions.com

CUSTOMER DUE DILIGENCE (CDD) MEASURES

The Individual

Adherence to the approved Customer 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 customers who are not private individuals, such as corporate customers 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) which is 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) which is 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 Matters and Clients

We must carry out Enhanced Due Diligence in any case where there is a high risk of money laundering. The law says that includes the following.

• We are dealing with a person established in a high-risk country.
• 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.

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 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 are provided below.

Regular and existing customers

These are some of the questions we consider when deciding whether or not to submit a suspicious activity report in relation to regular and existing customers:

•The transaction is different from the normal business of the customer

•The size and frequency of the transaction is different from the customer’s normal pattern

•The pattern has changed since the business relationship was established

•The nature of any payments made changes; for example, a buyer’s payment to an auctioneer is made in cash rather than through a bank account

•There has been a significant or unexpected improvement in the customer’s financial position the customer cannot give a proper explanation of where money came from or their source of wealth or funds.

Transactions

These are some of the questions we consider when deciding whether or not to submit a suspicious activity report in relation to the transactions carried out:

• A third party, apparently unconnected with the seller or buyer, bears the costs, or otherwise pays the transaction costs

• An unusually big cash or foreign currency transaction
• The buyer will not disclose the source of the funds or the seller source of wealth where required
• Unusual involvement of third parties, or large payments from private funds, particularly where the buyer appears to have a low income • Unusual source of funds.

WARNING: Suspicious activity will be reported to The National Crime Agency (NCA)

RECORD KEEPING

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 had lapsed.

In consideration of our carbon footprint, copies of all personal data and any documents procured for the purposes of identity verification will be stored electronically and will not be used for any other purpose.

IF YOU HAVE ANY QUESTIONS REGARDING OUR ANTI MONEY LAUNDERING POLICIES AT FORTRESS PROPERTY SOLUTIONS LTD, PLEASE CONTACT OUR MONEY LAUNDERING REPORTING OFFICER (MLRO).

Please do hesitate to contact us by email at info@fortresspropertysolutions.com or by phone on 0203 1461 786 if you require any further advice or have any queries or visit our website on www.fortresspropertysolutions.com

Fortress Property Solutions Ltd Anti-Money Laundering Registration Number is

XJML00000182571