Anti-Money Laundering & Financial Sanctions Policy (Summary)

Stephenson Browne Ltd is committed to preventing money laundering, terrorist financing and
breaches of UK financial sanctions across all areas of our business, including estate agency
and lettings.

We comply with the Proceeds of Crime Act 2002, the Terrorism Act 2000, the Sanctions and
Anti-Money Laundering Act 2018 and the Money Laundering, Terrorist Financing and Transfer of
Funds (Information on the Payer) Regulations 2017 (as amended).

What This Means in Practice
 

• We assess the risk of money laundering and terrorist financing within our business.
• We verify the identity of our clients where required by law.
• We carry out sanctions screening against the UK sanctions list.
• We monitor transactions and apply enhanced checks where higher risks are identified.
• We provide regular training to our staff.
• We report suspicious activity to the appropriate authorities where required.

Estate Agency

Our estate agency work is fully subject to the Money Laundering Regulations and supervised by
HM Revenue & Customs (HMRC).

Lettings

Where required by law, we conduct customer due diligence for qualifying high-value lettings.
Regardless of rental value, we comply with UK financial sanctions legislation in all lettings
transactions.

Reporting Concerns

Our Money Laundering Reporting Officer (MLRO) is Stephen Bird.
Our Deputy MLRO is Bethany Mullins.

All staff are trained to recognise and report suspicious activity. Where appropriate, reports are
made to the National Crime Agency (NCA) and/or the Office of Financial Sanctions
Implementation (OFSI).

This policy is reviewed regularly to ensure it remains up to date with current legislation.