Inigo Guide to: Anti-Money Laundering Checks for Buyers

Hello and congratulations on having your offer accepted! Before we can formally proceed with the sale, we are required by law to carry out Client Due Diligence (CDD) process in line with Anti-Money Laundering (AML) regulations. We understand that the information you share with us during this process is sensitive. This guide is designed to help you understand what we need from you, why we need it, and the actions we take to ensure that your information is secure.

Please review the information below and ensure you have read the Data Security and How To Upload Your Documents section before proceeding. If you have any questions or concerns, please don’t hesitate to ask your Sales Advisor for more information.

Under current AML regulation, we are obliged to run identity checks on any individual with whom we enter a business relationship. In practice, this means acquiring a certified Proof of Identity document and a separate Proof of Address document for every person involved with the purchase of a home. Please note that the same Proof of Address document cannot be used for more than one person.

We can accept the following documents as Proof of Identity:

• Current signed passport
• UK driver’s licence (provisional licences are not accepted)*
• National identity card
• Residence permit

We can accept the following documents as Proof of Address:

• Utility bill dated within the last 3 months (e.g. gas, electricity, water)
• Council Tax bill for the current tax year
• Bank statement dated within the last 3 months*
• UK Driver’s Licence (provisional licences are not accepted)*

*Please note that you cannot use the same document for more than one part of the due diligence process. For example, you cannot use bank statements from the same account for both Proof of Address and Proof of Funds. Similarly, a Driver’s Licence cannot be used for both Proof of Address and Proof of Identity simultaneously.

If you are unable to provide any of the above, please get in touch and we can discuss your options for alternative documents.

Please note that we cannot accept the following as Proof of Address:

• Credit card bill
• General correspondence from a bank or local authority
• Mobile phone or broadband bill

Depending on how you are funding your purchase, we will need different documents to verify your Proof of Funds. To comply with AML regulations, we are also required to verify beyond reasonable doubt that your funds have come from a legitimate source – the documents we must acquire for this purpose are what we refer to as Source of Funds.

To verify Source of Funds, we adopt a risk-based model whereby each client’s profile is considered on a case-by-case basis with reference to current AML guidance for estate agents and our own risk profile as a business.

The summaries below are intended to give you an overview of what we will ask for up front when you tell us how you are funding your purchase. Please be aware we may ask for additional documents in order to fill out your profile depending on the details of the documents you provide.

Mortgage or Remortgage

If you are funding your purchase with a mortgage, we must see a copy of your Agreement in Principle (AIP) from your mortgage broker. If your lender does not issue AIPs, we can also accept a letter from your mortgage broker confirming that they have assessed your financial situation to verify that they are confident in your ability to secure a loan of the appropriate size to proceed with your purchase.

Please note that you must be able to provide proof of cash funds for at least 10% of the agreed price on your offer regardless of the size of your mortgage.

Cash Funds

We require Proof of Funds to cover the cash portion of your purchase in its entirety. For example, if you are funding your purchase entirely with liquid assets, we will need to see bank statements with totals adding up to the purchase price. Please see the section below regarding Shares/Investments if you are purchasing using funds currently held in investments or savings portfolios.

For us to be able to accept them, any bank/investment statement(s) must show:

• The name of the buyer/giftor(s)
• The name of the bank/building society/investments manager
• The total balance amounts
• A date of issue within the last 3 months

Please note that while we can sometimes accept screenshots from online banking apps to verify your possession of funds when submitting a competitive offer, we cannot accept these screenshots as part of the due diligence process.

If you are having trouble acquiring relevant statements showing the required details, please get in touch with your Sales Advisor for advice on how to proceed.

Shares/Investments

If your shares and investments are in the UK, we will require a copy of your most recent share statement or share portfolio statement.

If your shares and investments aren’t held in the UK, we will require 3 months’ worth of stocks/shares statements dated within the last 3 months.*

Alternatively, we can accept written confirmation from your Financial Advisor that confirms you have access to sufficient funds for your purchase and that these will be available ahead of completion.

*Please note that if your shares and investments are held in one of the countries listed as High Risk by HMRC, we may be obliged to conduct further checks on your Source of Funds. Get in touch with your Sales Advisor for more information.

Pension Funds

If you are purchasing a property with pension funds, we will need a letter from your provider confirming the release of the funds. If the funds are yet to be released, we can accept a copy of your latest pension statement dated within the last 12 months. To be accepted, either document must confirm your name and address, as well as confirmation that the funds have been released or, if the funds are yet to be released, confirmation that pension funds will be available for the completion of the sale.

Gifted Funds

If any portion of your purchase funds is being gifted to you, we require proof of funds for the person(s) making the gift (your Giftor).

The same Proof/Source of Funds protocol that applies to Buyers also applies to Giftors.

In addition to Proof/Source of Funds documentation, we also require a written statement from the Giftor(s) confirming the following:

• They do not require the money to be repaid
• They are giving the gift to assist with the purchase of a property
• They do not expect to have any legal or beneficial interest in the property
• They will not be living in the property

Your Giftor(s) can provide this statement to us by email, or via Thirdfort as part of their identity check.

Inheritance

If some or all your funds are coming from an inheritance, we will require confirmation from the executor/solicitor of the amount that is inherited and when this is being released.

If the funds have been released already, we will require a copy of your bank account statement showing the money being received from the solicitor/executor’s bank account. If the relevant statement is older than 3 months, we will also require a recent statement (within 3 months) demonstrating that you still have access to the relevant funds if not already provided.

Cash from the sale of a home

If your funds are coming from the sale of your property, we will require a copy of the Memorandum of Sale and contact details for the managing agent. We will then speak directly with the agent to verify the chain details if we haven’t already done so.

If the sale has completed, we will require a copy of the Memorandum of Sale and a bank statement showing the funds arriving in your account. If the relevant statement is older than 3 months, we will also require a recent statement demonstrating that you still have access to the relevant funds if not already provided. Alternatively, if your solicitor is holding the funds from your sale in anticipation of your purchase with us, we can accept written confirmation from your solicitor that they are holding the funds from the sale.

Please note that prospective funds from the sale of a property which is currently on the market without active offers cannot be accepted as a substantive part of your Proof of Funds.

If you are buying a property in the name of a Trust or a Company or are receiving funds loaned or extracted from a Trust or Company, please be aware that we will refer you to our compliance management partner, FCS Compliance, to complete all our required Anti-Money Laundering checks. Please be prepared to provide a point of contact for the Trust or Company who is able to provide any relevant business documents.

Please note that while we take every care to anticipate the most efficient way of carrying out due diligence, each client’s circumstances are unique, and in some cases we may need to request more detailed information or refer you to our compliance partner, FCS Compliance, in order to meet our obligations.

If you happen to be aware that your circumstances are complex (e.g. you if you are funding your purchase with funds originating from a business or from a High Risk Third Country), please let us know as early as you can so that we can plan appropriately to make the process as smooth as possible.

If you are unsure whether your situation is likely to be considered complex, please do not hesitate to contact your Sales Advisor, who will be able to refer your query to our Due Diligence team for advice.

To make the due diligence process as quick and convenient as possible, we have teamed up with Thirdfort. Thirdfort provides a secure, app-based platform that lets you send us your documents securely and even verify your ID remotely, meaning you don’t need to visit our offices or the Post Office to certify your documents in person.

Once your offer has been accepted, you will receive a link to download the Thirdfort app via your smartphone or tablet. The app will then guide you through the process of uploading your ID and Proof of Address, followed by a quick selfie. It will also prompt you to complete a Source of Funds Questionnaire and, if relevant, complete a Giftor’s Statement.

If in the course of your Due Diligence checks we ask you to provide us with additional documents, we recommend uploading these via the ‘Additional Documents’ section in Thirdfort as this is the most secure way of sharing them with us.

If for any reason you are unable to use Thirdfort, for example if you do not have or cannot use a smartphone, please get in touch with your Sales Advisor to discuss options for alternative arrangements. Please do not send documents directly by e-mail without telling us first, as doing so carries a greater risk for your data.

You can read more about how Thirdfort handles your data here.

Please note that we are required under AML regulations to hold your information for at least 5 years following the end of our business relationship in case of a government audit. We hold your information in our secure, industry-standard CRM, and all our staff are bound by Non-Disclosure Agreements concerning client information to protect your privacy.

If you have any more questions or queries about how we handle your information, please do not hesitate to get in touch.