Tom Molloy Property Group Ltd (Trading as TM Property Group)
 

1. Purpose

Tom Molloy Property Group Ltd is committed to preventing money laundering and terrorist financing in line with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended. This policy outlines the controls and procedures we have in place to identify, prevent, and report suspicious activity.

2. Our Obligations

As an estate agency business, we are legally required to:

• Carry out Customer Due Diligence (CDD)
   
• Conduct Ongoing Monitoring of clients
   
• Maintain accurate records
   
• Report suspicious activity to the National Crime Agency (NCA)
   
• Appoint a Nominated Officer to oversee compliance
   

3. Customer Due Diligence (CDD)

We are required to verify the identity of:

• Sellers
   
• Buyers
   
• Landlords
   
• Tenants, in certain situations
   
• Any beneficial owners of companies or trusts involved in a transaction
   

Acceptable forms of identification include:

• Photo ID (e.g., valid passport or driving licence)
   
• Proof of address (e.g., utility bill or bank statement dated within the last 3 months)
   
• Proof of ownership or link to property (e.g., Title Deeds, rent statement)
   

We may also carry out electronic verification through trusted third-party providers.

4. Enhanced Due Diligence (EDD)

We will apply Enhanced Due Diligence measures if:

• The customer is not physically present
   
• The customer is a Politically Exposed Person (PEP)
   
• The transaction involves a high-risk country
   
• We identify red flags or suspicious behaviour
   

5. Suspicious Activity Reporting

Any suspicious transactions or activity must be reported to our Nominated Officer, who will determine whether a Suspicious Activity Report (SAR) should be filed with the NCA.

Red flags may include:

• Reluctance to provide ID
   
• Unusual funding sources or payment patterns
   
• Seemingly unnecessary involvement of third parties
   
• Inconsistencies in documentation
   

6. Record Keeping

We are required to keep records of:

• Identification documents
   
• Communication records
   
• Transaction details
   
• Any SARs submitted
   

These records will be retained for five years from the end of the business relationship or transaction.

7. Staff Training

All relevant staff receive ongoing AML training to ensure they understand how to:

• Recognise suspicious activity
   
• Follow correct identification procedures
   
• Escalate concerns to the Nominated Officer
   

8. Nominated Officer

Our appointed Nominated Officer is:
Tom Molloy
Managing Director
Email: info@tmpropertygroup.com
Phone: 0121 798 1378

The Nominated Officer is responsible for overseeing AML compliance, investigating reports internally, and liaising with the National Crime Agency (NCA) where necessary.

9. Review

This policy is reviewed annually or as required by changes in legislation or business operations.

Company Information:
Tom Molloy Property Group Ltd (Trading as TM Property Group)
Company Number: 15408224
VAT Number: 474616275
Registered Office: 1310 Solihull Parkway, Birmingham Business Park, B37 7YB
Member of the ICO and the Property Redress Scheme