Anti-Money Laundering (AML) Risk Assessment and Policies

Prepared for YATIRIM UK LIMITED

1. Risk Assessment Document

A. Business Profile

Business Name: YATIRIM UK LIMITED

Business Type: Real Estate

Activities:

• - Buying, selling, or managing residential and commercial properties.
• - Facilitating real estate transactions.

B. Risk Factors

1. Customer Risk:

• - Dealing with buyers/sellers of high-value properties.
• - Clients using complex ownership structures (e.g., trusts or offshore companies).

2. Geographic Risk:

• - Transactions involving overseas buyers, especially from high-risk jurisdictions.
• - Exposure to regions with higher risks of financial crimes.

3. Transaction Risk:

• - High-value property sales.
• - Transactions involving unusual payment methods or third-party payers.

C. Risk Mitigation Measures

• - Perform due diligence on all property transactions.
• - Limit cash transactions; prioritise bank transfers.
• - Conduct enhanced checks for overseas clients or large deposits.

D. Risk Assessment Summary

Customer Risk: Medium

Geographic Risk: Medium-High (depending on client location)

Transaction Risk: High

2. AML Policies and Procedures

A. Key Policies

1. Customer Due Diligence (CDD):

• - Verify identity and address for all clients.
• - Screen clients against sanctions and Politically Exposed Persons (PEP) lists.

2. Enhanced Due Diligence (EDD):

• - Apply additional checks for complex ownership structures or clients from high-risk countries.

3. Ongoing Monitoring:

• - Continuously review customer activities for red flags (e.g., payments from unrelated third parties).

4. Record Keeping:

• - Maintain records of due diligence checks and property transactions for at least 5 years.

5. Reporting Suspicious Activity:

• - Appoint a Money Laundering Reporting Officer (MLRO).
• - Report suspicious activities to the National Crime Agency (NCA) via SARs.

B. Procedures

1. Onboarding Customers:

• - Obtain proof of ID (passport, driver's licence) and address (utility bill, bank statement).
• - Check for PEP or sanctions matches.

2. Handling Transactions:

• - Only accept payments through traceable methods (e.g., bank transfers).
• - Flag transactions over £10,000 or involving foreign payers for enhanced checks.

3. Training Employees:

• - Provide regular AML training tailored to real estate risks.
• - Keep records of training completion.

4. Responding to Suspicious Activity:

• - Notify the MLRO immediately if red flags arise.
• - Submit a SAR within 24 hours if suspicious activity is identified.

5. Periodic Review:

• - Update the risk assessment annually.
• - Conduct internal audits of AML compliance processes.