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). We also maintain our policies, procedures and controls in line with current guidance issued by HM Revenue & Customs (HMRC), the National Crime Agency (NCA), the Office of Financial Sanctions Implementation (OFSI) and other relevant UK authorities. Our compliance framework is reviewed and updated to reflect legislative, regulatory and sanctions-related developments. 

What This Means in Practice
 

1. We assess the risk of money laundering, terrorist financing and sanctions breaches within our business.
2. We verify the identity of our clients where required by law.
3. We carry out sanctions screening against the UK sanctions list and other relevant government notices.
4. We monitor transactions and apply enhanced due diligence and ongoing monitoring where higher risks are identified.
5. We maintain risk-based policies, controls and procedures designed to prevent financial crime.
6. We provide regular training to our staff to ensure awareness of current legal and regulatory requirements.
7. We report suspicious activity and sanctions concerns 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). We apply a risk-based approach to customer due diligence, ongoing monitoring and record keeping in accordance with current legislation and regulatory guidance. 

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 and undertake sanctions screening where appropriate.

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).

Policy Review

This policy is reviewed at least annually and whenever there are significant changes to applicable legislation, HMRC guidance, financial sanctions requirements or regulatory expectations. This ensures our policies, procedures and controls remain effective, proportionate and up to date.