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Location

Head Office: 303 Romford Rd, London E7 9HA, United Kingdom

Anti-Money Laundering Policy

Money Laundering Regulations 2017

Pure Estates is fully committed to the prevention of money laundering and terrorist financing. This policy outlines our verification requirements and your obligations as a client.

Our Legal Obligation

As a UK estate agency and property management firm, Pure Estates is legally required to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended). We are supervised by HMRC and must conduct appropriate customer due diligence (CDD) before providing any services, including property lettings, management, or business transfers.

Required Verification Checks

To comply with the law, we must obtain and verify specific information from all clients (landlords, tenants, sellers, and buyers) before we can act for them. We use a combination of electronic verification and physical document checks.

Identity (ID)

We require a valid government-issued photographic ID, such as a passport, UK driving licence, or national identity card (for EEA nationals). For non-EEA clients, we may request a residence permit or visa documentation.

Proof of Address

A recent (within 3 months) utility bill, council tax bill, bank statement, or tenancy agreement showing your current residential address. We cannot accept PO boxes or business addresses for this purpose.

Source of Funds

For any transaction involving money (e.g., rent payments, deposit, purchase funds), we will ask where the money comes from. Evidence may include payslips, bank statements showing salary, investment statements, or gift letters (with donor's ID).

Source of Wealth

In higher-risk situations or where significant funds are involved, we may need to understand how you accumulated your overall wealth. This could include property sales, inheritance, business ownership, or other lawful means.

Examples of Acceptable Documents

✅ Identity verification (one of the following):

  • Valid passport (any nationality)
  • UK photo driving licence (full or provisional)
  • National identity card (EEA/Swiss nationals)
  • Biometric residence permit (UK)

✅ Proof of address (one of the following, dated within 3 months):

  • Utility bill (gas, electricity, water, landline – not mobile)
  • Council tax bill
  • Bank, building society, or credit card statement
  • HMRC tax notification or letter
  • Tenancy agreement or mortgage statement

✅ Source of funds / wealth evidence (examples):
Payslips (3 months), business accounts, sale of assets contract, inheritance grant, divorce settlement, gift deed plus donor's ID and bank statement.

Our Right to Refuse or Cease Acting

⚠️ Important: Pure Estates reserves the unconditional right to refuse to provide services (or to terminate an existing instruction) if you fail to provide satisfactory verification documents within a reasonable timeframe. We cannot accept cash or any funds without full source of funds verification.

If we are unable to complete customer due diligence to our satisfaction, we will not proceed with any letting, management, or transaction. This is a strict legal requirement, not a commercial choice.

In cases where verification is not provided after a formal request, we will:

  • Notify you in writing explaining the deficiency.
  • Give a final deadline (usually 10 working days) to comply.
  • If still unresolved, terminate our instruction and decline to act further.
  • In certain circumstances, we may be legally required to file a Suspicious Activity Report (SAR) with the National Crime Agency (NCA) – we cannot disclose this to you if it occurs.

How We Verify Your Information

Pure Estates uses a combination of:

  • Electronic ID verification (via secure, GDPR-compliant providers) to check passports, driving licences, and address history instantly.
  • Manual document checks for physical copies where required.
  • Third-party databases for politically exposed persons (PEPs) and sanctions screening.

All checks are carried out securely and information is retained only as long as required by law (typically 5 years after the business relationship ends).

Ongoing Monitoring

Our AML obligations do not end at onboarding. We may conduct periodic reviews of your verification documents (particularly for ongoing management clients) and will request updated information if your circumstances change or if a new transaction requires additional scrutiny.

Data Protection & Confidentiality

All personal data collected for AML purposes is processed in strict accordance with UK GDPR and our Privacy Policy. We will never share your verification documents with unauthorised third parties, except where required by law (e.g., HMRC, NCA, or court order).

Reporting Suspicion

All Pure Estates staff receive regular AML training. If we suspect money laundering or terrorist financing, we are legally obliged to report our suspicion to the National Crime Agency (NCA) without informing you. This is known as ‘tipping off’ protection and we strictly adhere to it.

🔒 Confidentiality note: If we file a Suspicious Activity Report (SAR), we are prohibited from disclosing that fact or any related details to the person involved. We trust you understand that this is a legal requirement designed to protect the financial system.

Your Responsibilities as a Client

  • Provide accurate, complete, and up-to-date verification documents when requested.
  • Inform us immediately if any of your information changes (e.g., new passport, address, or source of funds).
  • Never attempt to use cash for property transactions – we do not accept cash payments.
  • Cooperate fully with any additional requests for information, especially for source of funds or source of wealth.

📞 For questions about our AML policy or to submit verification documents, contact our Money Laundering Reporting Officer (MLRO) at info@pureestates.com or call 0208 555 2550.

Last updated: 1st May 2026. This policy is reviewed annually and complies with the Money Laundering Regulations 2017, POCA 2002, and Terrorist Asset Freezing Act 2010.