Anti-Money Laundering Policy

Latchkey & Vault Limited is committed to ensuring that it has adequate controls to counter money laundering activities and terrorist financing activities, in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Risk assessments will be carried out within our policies and procedures to help prevent money laundering and terrorist financing.

This risk-based approach is where we assess the risk of customer’s laundering money through our business activities. Although we accept that the majority of our customers will not launder money, we must identify criteria that would indicate a higher risk of money laundering. An example of this is where we do not meet the client face-to-face at any point during the transaction.

As part of mitigating the risk Latchkey & Vault Limited recognises that it is essential for all staff to receive training in anti-money laundering legislation and as such all staff are trained to understand the company’s responsibilities and how to identify risk. Each member of staff is also provided with a copy of this Money Laundering Policy as a reminder of their responsibilities and where/how to report suspicious circumstances.

Adherence to the “Due Diligence” identification procedures on every occasion will mitigate the risks of the business being used to launder money or fund terrorism. We recognise that under the regulatory guidance we can do this by either taking paper documentation or running an appropriate electronic Anti Money Laundering check.

The regulations identify that “Due Diligence” should be carried out on our “Client” and are required because we deal with one off transactions of €15000 or more. The customer we must identify is the beneficiary of the transaction, identified as anyone who owns or controls 25% or more of the property. Therefore all (Vendors/ Landlords) will be subject to an Anti-Money Laundering check. Should the check be unsuccessful we will then seek further identification through approved documentation.

This policy and our procedures will be reviewed annually to ensure they adequately reflect the risk of money laundering to the company.

To identify the client, we will collect documents in line with the following which is stipulated by the regulatory guidance. A government issued document with the customer’s full name and photo with either the customer’s date of birth or residential address such as: Valid passport Valid photo card driving licence National identity card Firearms certificate A government issued document (without a photo) which includes the customer’s full name and supported by secondary evidence: Old style driving licence Recent evidence of entitlement to state or local authority-funded benefit such as housing benefit, council tax benefit, pension, tax credits Supported by secondary evidence such as: A utility bill Bank or building society statement Most recent mortgage statement from a recognised lender

For customers who are not private individuals, such as corporate customers and private companies, the business must obtain information that is relevant e.g. company registration number, registered address and evidence that the individuals have the authority to act for the company – a search at Companies House will reveal details of directors and the Company Secretary. If subsequently we identify a person who has control of/owns 25% or more the business, we will take steps to identify those individuals.

WARNING: We will report all suspicious activity to The National Crime Agency (NCA)