At Naomi Spencer Estates Limited, we are committed to upholding the integrity of the UK property market by preventing financial crime and complying with all Anti-Money Laundering (AML) regulations.
1. Why AML Matters
The UK property sector is a known target for money laundering due to the high value of transactions. Estate agents are legally required to help prevent criminal funds from entering the market by conducting thorough checks on clients and transactions. Our AML procedures help protect the market, our clients, and the wider community.
2. Who Is a Client?
For the purposes of AML checks, all individuals and entities engaging with us are considered clients — including vendors (property sellers) and purchasers on acceptance of offer. We are legally required to conduct checks on both parties to ensure full regulatory compliance.
3. What We Do
Customer Due Diligence (CDD)
We carry out identity verification using official documentation such as:
- Passports or driving licences
- Recent utility bills or bank statements (as proof of address)
To streamline this process and ensure accuracy, we use SafeSearch, a secure digital verification platform recognised by HMRC. SafeSearch allows us to verify identity and address information quickly and efficiently, while maintaining high standards of data protection.
Source of Funds Verification
We request documentation that demonstrates how the funds used in property transactions were obtained. This may include:
- Bank statements
- Sale agreements (e.g. from another property)
- Inheritance paperwork or gift letters
Beneficial Ownership Checks
If you’re acting on behalf of someone else, or representing a company or trust, we are required to identify and verify the ultimate beneficial owner.
Ongoing Monitoring
Client relationships and transactions may be monitored on an ongoing basis, particularly when circumstances change or risk factors emerge.
Suspicious Activity Reporting
Should we suspect that a transaction or behaviour is linked to money laundering, we are required to submit a Suspicious Activity Report (SAR) to the National Crime Agency.
4. What’s Required of Our Agency
To meet our obligations, Naomi Spencer Estates Limited:
- Is registered with HMRC for AML supervision
- Maintains an internal AML policy and risk assessment, reviewed annually
- Appoints a Nominated Officer responsible for overseeing compliance and reporting
- Delivers staff training to ensure awareness and understanding of AML procedures
- Uses digital tools, including SafeSearch, to enhance the accuracy and efficiency of checks
- Stores client records and AML documentation securely for at least five years
- Applies enhanced due diligence for high-risk clients, including Politically Exposed Persons (PEPs)
5. Your Role as a Client
We understand that these checks may feel intrusive, but they are a legal requirement under UK regulations. By cooperating with us and providing accurate documentation, you help ensure a safe, fair, and transparent property process.
6. Our Commitment
Naomi Spencer Estates Limited views AML compliance not just as a legal duty, but as a cornerstone of our values. We are committed to protecting our clients and operating with honesty, clarity, and care in every transaction.