1. Policy Statement

Highlight Housing Limited is fully committed to complying with its legal obligations under the Money Laundering Regulations 2017 (as amended), Proceeds of Crime Act 2002, Terrorism Act 2000, and Section 1 of the Estate Agents Act 1979. As part of this commitment, we are registered with HMRC for Money Laundering Supervision, as required for all estate agents operating in the UK.

Our policy aims to prevent the use of our services for money laundering or terrorist financing and ensure that our operations maintain the highest levels of transparency and integrity.

2. Scope

This policy applies to all employees, contractors, and partners involved in property transactions or lettings. It establishes procedures for identifying, reporting, and mitigating money laundering risks in compliance with HMRC Money Laundering Supervision requirements.

3. Responsibilities

• Money Laundering Reporting Officer (MLRO): The appointed MLRO is responsible for overseeing AML compliance, receiving suspicious activity reports (SARs), and liaising with HMRC and the National Crime Agency (NCA).

• Employees: All staff must comply with AML procedures and report any suspicious activities to the MLRO.

4. Customer Due Diligence (CDD)

In accordance with HMRC supervision requirements, we will conduct CDD on all clients, including:

• Verifying the identity of individual clients using official documents (e.g., passport, driving license, utility bills).

• Identifying beneficial owners for corporate clients.

• Establishing the purpose and nature of the business relationship.

Enhanced Due Diligence (EDD) will be applied for higher-risk clients, such as politically exposed persons (PEPs) or clients from high-risk jurisdictions.

5. Risk Assessment

We will regularly assess risks associated with money laundering and terrorist financing. This includes evaluating risks in:

• High-value property transactions.

• Clients or funds originating from high-risk countries.

• Unusual or complex transaction structures.

6. Record Keeping

In compliance with HMRC requirements, we will securely retain records of all CDD checks, transaction details, and communications for a minimum of 5 years after the end of the business relationship. These records will be readily accessible for HMRC audits and inspections.

7. Training

All employees will undergo regular training on AML requirements, including recognising suspicious activities, conducting due diligence, and reporting procedures. This training ensures compliance with HMRC Money Laundering Supervision standards.

8. Reporting Suspicious Activities

Staff must report any suspicious transactions or behaviors to the MLRO. The MLRO will assess the reports and, where necessary, submit a Suspicious Activity Report (SAR) to the NCA. HMRC will be notified of any breaches of AML procedures during routine compliance checks.

9. Monitoring and Review

This policy will be reviewed annually or when significant regulatory updates occur to ensure ongoing compliance with HMRC requirements and the Estate Agents Act 1979. Internal audits will be conducted to evaluate the effectiveness of AML procedures.

10. Consequences of Non-Compliance

Failure to comply with AML regulations or HMRC Money Laundering Supervision requirements can result in significant penalties, including fines, imprisonment, and deregistration. Employees failing to adhere to these policies may face disciplinary action, up to and including termination of employment.

By adhering to this AML policy, Highlight Housing Limited reaffirms its commitment to preventing money laundering and complying with its obligations under HMRC Money Laundering Supervision and the Estate Agents Act 1979.