Anti-Money Laundering Policy
Introduction
Marco Harris, known legally as CFH PROPERTY GROUP LIMITED, prioritises stringent anti-money laundering (AML) practices and is dedicated to preventing its services from being utilised for money laundering or financing terrorism. This commitment aligns with the directives outlined in the Money Laundering, Terrorist Financing & Transfer of Funds (Information on the Payer) Regulations 2017, including all subsequent updates. For ensuring compliance, Marco Harris is registered with and regulated by HM Revenue & Customs.
Commitment to Compliance
- Risk Management: Understanding our clientele and their transaction behaviours is paramount. By conducting comprehensive risk assessments, Marco Harris identifies potential high-risk scenarios for money laundering and terrorist financing, adopting, and documenting requisite measures to mitigate these risks effectively.
- Employee Education: Our team undergoes extensive training to grasp the nuances of AML legislation thoroughly. Training initiatives encompass an introduction for new hires and continuous educational sessions to maintain awareness and competence in recognising and addressing potential AML concerns.
- Ongoing Audits: Regular compliance audits ensure adherence to our AML framework. Daily reviews of customer due diligence by our centralised administration set the foundation for immediate business engagements, with any necessary corrective actions or additional training promptly addressed.
Due Diligence Procedures
- For Individuals: Marco Harris employs advanced electronic verification, including next-generation facial recognition technology, for identity and document authenticity checks. If electronic verification fails, we follow up with document collection as guided by regulatory standards.
- For Entities and Trusts: Comprehensive due diligence extends to corporate entities, trusts, and other legal structures. This involves identifying and verifying ultimate and beneficial owners, obtaining relevant documents, and understanding the entity’s control and ownership structure.
- Probate Processes: In cases involving probate, we perform due diligence on executors or administrators in line with the individual verification procedures.
Suspicious Activity and Reporting
Any suspicions of money laundering or terrorist financing are escalated to our Money Laundering Reporting Officer (MLRO) or their deputy. They are tasked with reviewing cases and deciding on the submission of Suspicious Activity Reports (SARs) to the National Crime Agency, ensuring confidentiality throughout the process.
Record-Keeping Practices
In line with legislative requirements, Marco Harris retains all Customer Due Diligence records for a minimum of five years post the cessation of a business relationship or transaction completion. These records support our regulatory compliance and facilitate any investigations. Adhering to data protection laws and with a mindful approach to our environmental impact, all records are securely stored electronically.
Contact Information
- Money Laundering Reporting Officer (MLRO): Connor Harris
- Address: 68 Botley Road, Park Gate, Southampton, SO31 1BB
- Email: Connor@marcoharris.co.uk
Policy Maintenance
This policy, last revised in March 2024, supersedes all previous versions, reflecting our current practices and commitment to preventing money laundering and terrorist financing.