Anti Money Laundering Policy
Anti-Money Laundering and Sanctions Policy
Last updated: 20 May 2026
1. Introduction and purpose
Your Home Managed Ltd ("we", "us", "our") is committed to preventing money laundering, terrorist financing, and breaches of UK financial sanctions. This policy sets out the procedures we follow to identify, assess, and mitigate the risk that our services could be used to facilitate financial crime.
This policy reflects the law as in force at the date above and is reviewed at least annually, and whenever there is a material change in legislation or guidance.
2. Applicable legislation and guidance
This policy is designed to comply with our obligations under:
The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("MLR 2017")
The Proceeds of Crime Act 2002 ("POCA")
The Terrorism Act 2000
The Sanctions and Anti-Money Laundering Act 2018
The various UK financial sanctions regulations made under that Act
HMRC's guidance for estate and letting agency businesses on money laundering supervision
OFSI guidance for letting agents and other relevant firms
3. Scope — AML supervision and sanctions
There are two distinct regimes that apply to letting agents, and it is important to keep them separate.
3.1 AML supervision under MLR 2017
A letting agency business is within the scope of MLR 2017 where it acts on instructions to let property at a rent of €10,000 or more per month (or the sterling equivalent), with a tenancy term of one month or longer. Where we act in respect of any property meeting that threshold, we are registered with HMRC for AML supervision and apply the full Customer Due Diligence regime set out below.
For properties below the AML supervision threshold, MLR 2017 does not formally apply. However, we adopt Propertymark's recommended best practice and apply Customer Due Diligence to every landlord, tenant, and guarantor we deal with, regardless of rent level. This provides consistent protection for our business and our clients, and supports our sanctions obligations.
3.2 Financial sanctions
Since 14 May 2025, all UK letting agents have been classified as "relevant firms" under the UK financial sanctions framework, regardless of rent level. Sanctions screening and reporting obligations apply to every landlord, tenant, guarantor, and other party we deal with. This regime applies to us whether or not any individual property is within the AML supervision threshold.
4. Money Laundering Reporting Officer (MLRO)
We have appointed a Money Laundering Reporting Officer (MLRO) and a Deputy MLRO. The MLRO is responsible for:
Receiving and considering internal reports of suspicious activity
Deciding whether to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA)
Acting as the firm's point of contact with HMRC, the NCA, and OFSI
Maintaining our written AML risk assessment and policies
Overseeing staff training and record-keeping
Ensuring sanctions screening is carried out and recorded
Nominated officer: Louise Putt
All staff are required to report any concern, no matter how small, to the MLRO without delay.
5. Risk-based approach
We take a risk-based approach to AML compliance. We maintain a written firm-wide risk assessment that considers:
Customer risk (including country of residence, ownership structure, and PEP status)
Geographical risk
Product, service, and transaction risk
Delivery channel risk (in particular, non-face-to-face onboarding)
Each client relationship is risk-assessed at onboarding and revisited where material changes occur. The risk rating drives the level of due diligence we apply.
6. Customer Due Diligence (CDD)
We carry out CDD on all landlords, tenants, guarantors, vendors, and buyers we deal with. CDD involves:
Identifying the customer
Verifying identity from independent and reliable sources
Identifying any beneficial owner and taking reasonable steps to verify their identity
Understanding the nature and purpose of the business relationship
Conducting ongoing monitoring of the relationship
For Landlords and sellers we also require evidence of property ownership. Where we cannot complete CDD to our satisfaction, we will not proceed with the instruction or tenancy.
7. Enhanced Due Diligence (EDD)
We apply Enhanced Due Diligence where the risk of money laundering or terrorist financing is higher, including where:
The customer is a Politically Exposed Person (PEP), a family member of a PEP, or a close associate of a PEP
The customer is established in a high-risk third country listed by the UK
The customer or beneficial owner is not physically present for identification purposes
Adverse media checks identify cause for concern
The transaction is unusually complex, of unusual size, or has no apparent economic or lawful purpose
The customer is acting through nominees or unnecessarily complex structures
Enhanced measures include obtaining additional identification, source of funds and source of wealth information, senior management approval for the relationship, and increased ongoing monitoring.
8. Identity documents
We require all customers to provide identification in the form of one document from List A (identity) and one document from List B (proof of address). For landlords and vendors we additionally require evidence from List C (ownership). Original documents must be inspected by a member of staff with a copy retained; where this is not possible, copies must be certified by a solicitor, accountant, or other appropriate professional.
For prospective tenants who hold digital UK immigration status (including under the EU Settlement Scheme), we use the Home Office online right-to-rent share-code service in addition to the documents below.
List A — Identity
Current signed UK or international passport
Current UK photocard driving licence (full or provisional)
National identity card issued by an EEA member state or Switzerland (Right to Rent rules may impose additional requirements)
Biometric Residence Permit (BRP) or other Home Office immigration document, while still valid (the BRP is being phased out; we accept the Home Office online share-code service as an alternative)
HMRC tax notification (for example, P60 or recent HMRC correspondence)
Recent state pension or benefits notification letter
List B — Proof of address (dated within the last three months unless otherwise indicated)
Current UK photocard driving licence (if not used in List A)
Council tax bill for the current year
Benefits or state pension entitlement letter
Local authority tenancy agreement or rent statement
Tenancy agreement from a regulated letting agent
Bank, building society, or credit union statement
Mortgage statement (within the last 12 months)
Utility bill (gas, electricity, water, landline — not mobile)
Home or motor insurance certificate
NHS medical card or letter from a GP confirming registration
List C — Proof of ownership (for landlords and vendors)
Most recent mortgage statement
Buildings insurance certificate naming the insured
Solicitor's letter confirming purchase, or copy of the Land Registry title
Probate
If you are acting as a personal representative of an estate, we require:
Grant of Probate (where a will was left), or Letter of Administration (where there was no will)
Identity evidence from Lists A and B for the personal representative
UK companies
For corporate landlords or buyers we additionally require:
Certificate of Incorporation
Articles of Association
Latest Confirmation Statement showing current officers
Companies House register details
Identity evidence (Lists A and B) for each individual or entity holding 25% or more of the shares or voting rights, and for each individual exercising significant control
Nominee director declaration and Power of Attorney where applicable
Overseas companies
For overseas corporate landlords or buyers we additionally require:
Certificate of Incorporation
Articles of Association, Memorandum of Association, latest annual return with officers, and share certificates showing the ultimate beneficial owner, OR Certificate of Incumbency
Confirmation of registration with the UK Register of Overseas Entities at Companies House, where applicable
Identity evidence (Lists A and B) for each individual holding 25% or more of the shares or voting rights, and for each individual exercising significant control
Nominee director declarations and Powers of Attorney where applicable
For corporate shareholders, the same documentation again for each holding company in the chain
Trusts
For trusts we additionally require:
The Trust Deed
A list of trustees, settlors, and beneficiaries
Confirmation of registration with the HMRC Trust Registration Service where applicable
Identity evidence (Lists A and B) for each trustee, each named beneficiary entitled to 25% or more of the capital, and any individual exercising control over the trust
9. Beneficial ownership
We take reasonable steps to identify the ultimate beneficial owner of every corporate or trust customer. A beneficial owner is any individual who ultimately owns or controls 25% or more of the customer, or who otherwise exercises control over its management.
Where the ownership structure is layered or opaque, we treat the relationship as higher risk and apply Enhanced Due Diligence.
10. Politically Exposed Persons (PEPs) and adverse media
We screen all customers against PEP lists and conduct adverse-media checks using both commercial screening tools and reasonable public-source research. We document the result of the screening and the rationale for any decisions taken. Where a PEP, family member, or close associate is identified, we apply Enhanced Due Diligence and obtain senior management approval to proceed.
11. Financial sanctions screening
Since 14 May 2025, sanctions screening is a mandatory legal requirement for every letting agent in the UK, regardless of rent level. We screen every landlord, tenant, guarantor, and other relevant party against the OFSI Consolidated List of Financial Sanctions Targets in the UK before we accept an instruction or conclude a letting agreement.
We:
Carry out screening at onboarding
Re-screen annually, and whenever material changes occur in the customer's circumstances
Document the date of the check, the names searched, the source of the list, and the result
Pause onboarding immediately if we identify a possible match
Submit a report to the Office of Financial Sanctions Implementation (OFSI) where we know or reasonably suspect that a person is a designated person, that a breach of financial sanctions regulations has occurred, or that an obligation under sanctions regulations has not been complied with
Take immediate steps to freeze any funds or economic resources held for a sanctioned person, in accordance with OFSI guidance
Sanctions screening sits alongside, but is distinct from, our CDD obligations under MLR 2017.
12. Suspicious Activity Reports (SARs)
If at any stage we have knowledge or suspicion of money laundering, terrorist financing, or other reportable activity, we are legally required to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) at www.nationalcrimeagency.gov.uk.
Indicators of suspicion may include:
Reluctance to provide identification or evidence of source of funds
A transaction or valuation request well below or above market value
Payments offered in cash, or requests to hold cash in our client account
Intermediaries used to obscure the identity of the underlying customer
Funds being sent overseas to an unconnected third party without a clear reason
Use of unnecessarily complex ownership structures
A long-distance transaction where the buyer or landlord has not viewed the property
Late changes to the parties involved
A significant and unexplained improvement in financial position
An apparent unwillingness to demonstrate source of funds or wealth
Staff are required to escalate concerns to the MLRO and must not discuss them with the customer or any third party (see "tipping off" below).
13. Tipping off
It is a criminal offence under POCA to disclose to the customer (or to any third party) that a SAR has been or is being prepared, or that an investigation is being or may be carried out. Staff are trained on the tipping-off rules and on the limited circumstances in which disclosure within the firm or to a regulator is permitted.
14. Record retention
We keep records of all CDD, EDD, PEP and adverse-media checks, sanctions screening, internal SAR consideration, and any external reports, for the current tax year plus five years following the most recent transaction with the customer. Records are stored securely and are accessible only to authorised staff.
Records are retained even where we decline a relationship or a transaction, so that we can demonstrate the reasoning behind any decision.
15. Training
All relevant staff complete AML and sanctions training:
At induction, before they are allowed to onboard customers
Annually thereafter as a refresher
Whenever there is a material change in legislation, regulator guidance, or our internal policies
We use providers including Propertymark, the NRLA, and The Able Agent. Attendance, content covered, and competence assessments are recorded in the training log.
The MLRO additionally undertakes role-specific training to maintain technical knowledge of the sanctions framework, SAR reporting, and HMRC supervisory expectations.
16. Independent review and audit
Our policies, procedures, and controls are reviewed at least annually by the MLRO and senior management. Where required by Regulation 21 of MLR 2017 (size and nature of the business), we will commission an independent audit of the effectiveness of our AML controls.
17. Failure to comply
We take any failure to comply with this policy seriously. Breaches by staff may result in disciplinary action up to and including dismissal. Breaches by the firm may result in civil penalties, criminal prosecution, suspension or cancellation of HMRC supervision, and reputational damage.
18. Contact
If you have any questions about this policy or wish to raise a concern, please contact the MLRO:
Louise Putt, MLRO Your Home Managed Ltd C/O 1st Floor Cromwell House, 14 Fulwood Place, London WC1V 6HZ Email: info@yourhomemanaged.com Telephone: 020 8125 7780