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
- Customer Risk:
- – Dealing with buyers/sellers of high-value properties.
- – Clients using complex ownership structures (e.g., trusts or offshore companies).
- Geographic Risk:
- – Transactions involving overseas buyers, especially from high-risk jurisdictions.
- – Exposure to regions with higher risks of financial crimes.
- 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; prioritize 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
- Customer Due Diligence (CDD):
- – Verify identity and address for all clients.
- – Screen clients against sanctions and Politically Exposed Persons (PEP) lists.
- Enhanced Due Diligence (EDD):
- – Apply additional checks for complex ownership structures or clients from high-risk countries.
- Ongoing Monitoring:
- – Continuously review customer activities for red flags (e.g., payments from unrelated third parties).
- Record Keeping:
- – Maintain records of due diligence checks and property transactions for at least 5 years.
- Reporting Suspicious Activity:
- – Appoint a Money Laundering Reporting Officer (MLRO).
- – Report suspicious activities to the National Crime Agency (NCA) via SARs.
B. Procedures
- Onboarding Customers:
- – Obtain proof of ID (passport, driver’s license) and address (utility bill, bank statement).
- – Check for PEP or sanctions matches.
- Handling Transactions:
- – Only accept payments through traceable methods (e.g., bank transfers).
- – Flag transactions over £10,000 or involving foreign payers for enhanced checks.
- Training Employees:
- – Provide regular AML training tailored to real estate risks.
- – Keep records of training completion.
- Responding to Suspicious Activity:
- – Notify the MLRO immediately if red flags arise.
- – Submit an SAR within 24 hours if suspicious activity is identified.
- Periodic Review:
- – Update the risk assessment annually.
- – Conduct internal audits of AML compliance processes.
