Anti-Money Laundering Policy Statement

LH Estates Limited is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering Regulations 2007.

LH Estates Limited has a Money Laundering Reporting Officer whose responsibility is to receive internal reports.

Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism.

All purchasers and sellers must be identified fully with two forms of ID, evidence of identity being photographic and also evidence of residence e.g. a utility bill dated in the last three months.

Should a face to face meeting not take place then enhanced due diligence procedures will need to be adopted by asking for additional information or evidence to establish the customer’s identity, and ensuring that the documents supplied are certified. It would also be prudent to ensure that the first payment is made to a bank account in the customer’s name.

If the verification of the customer’s identity is done by documents this should be based on:

• A government issued document with the customer’s full name and photo with either the customer’s date of birth or residential address such as:

1. Valid passport
2. Valid driving licence
3. National identity card

• A government issued document (without a photo) which includes the customer’s full name and supported by secondary evidence such as

1. A utility bill
2. Bank or building society statement
3. Most recent mortgage statement from a recognised lender

For customers other than private individuals

For customers who are not private individuals, such as corporate customers and private companies, the business must obtain and present information that is relevant e.g. company registration number, registered address and evidence that the representatives of the said business have the authority to act for the business. Relevant searches will be carried out to confirm the details of the directors and company secretary.

Record Keeping

The following records are required to be kept for 5 years:

• Copies of, or references to, the evidence obtained of a customer’s identity for five years after the end of the customer relationship, or five years from the date when the transaction was completed.
• Supporting records relating to a customer relationship or occasional transaction for five years from the date when the transaction was completed.

The purpose for keeping these records is to demonstrate the business’s compliance with the regulations and to aid any resulting investigations.