HM Revenue and Customs (HMRC) have a number of Anti-Money Laundering Compliance Officers working through registered agencies to ensure that each business is up to date with their compliance activities.
There are a number of regulations and obligations which Estate Agents have to adhere to before, during and proceeding a property transaction. Every agent must have an appointed Money Laundering Reporting Officer (MLRO) who will the person responsible for ensuring that the compliance practices are in place and are being carried out.
I would recommend that the MLRO or any deputy in place ensure that they are prepared for possibly receiving a call from the HMRC.
What you can expect from a call
The calls will begin with some initial security questions before progressing to discuss:
- day-to-day business activities,
- procedures for vendor ID, (i.e. what processes do you have in place to verify identification of your clients),
- queries regarding record keeping, and
The purpose of the calls
The calls are intended to provide HMRC with the opportunity to decide whether a visit is required to clarify any issues that have arisen during the call. Responses to the enquiries will therefore enable HMRC to understand which estate agencies are fully aware of the obligations under the Money Laundering Regulations and those that are not.
Not only is it therefore important to ensure that you are compliant with the Regulations, but also that all staff are aware that HMRC may call at any time and that the call must be transferred through to your MLRO or, if the MLRO is absent, the Deputy MLRO.
If you receive a call and HMRC contact you indicating that they intend to visit, it is vital that you are fully prepared for the visit and have all of your records up to date.
Should you require any help to update your policy documents or to prepare for a visit, please contact me on 01604 828270 or firstname.lastname@example.org