Anti-Bribery and Corruption Policy
As part of a number of laws, Purple Frog Asset Management Limited (Purple Frog) is required to take various steps to reduce the risk that our services are used to enable criminals to launder money.
Government guidance advises that our responsibilities fall into the following categories:
– Risk assessment
– Customer due diligence
– Reporting suspicious activity
– Record keeping
– Staff awareness and training
Purple Frog is required to be supervised by HMRC for Anti Money Laundering.
Our registration number is: XWML00000179778
3. Risk Assessment
If any of the below issues apply to a client or transaction and imply high risk at any point of the transaction or relationship with the client, the employee concerned should refer to the MLRO before continuing to act for the client.
STATUS OF CLIENT
· Is the client known to Purple Frog personally/existing client, or new business relationship?
· Has our client been introduced to Purple Frog by a 3rd Party? Is S.17 reliance being used?
· Is the instruction from our client channelled through a 3rd party? If so, why?
· Is our client a politically exposed person?
· If our client is not a natural person but rather a legal entity, do we have full visibility and ID&V of beneficial owners and directors / controllers?
FACE TO FACE CONTACT
· Have we met with our client face to face or is it a non-face to face transaction?
· If non-face to face, are we comfortable there is a legitimate reason for this?
LOCATION OF CLIENT
· Where is our client based? Locally /UK/EU/other international location?
· Are you aware of our client having any links to criminality?
· Is our client based in a high risk jurisdiction or resident in/links to a sanctioned country?
ID & ADDRESS VERIFICATION
· Has our client provided acceptable standard ID and address verification?
· Has our client provided acceptable non-standard ID and address verification?
· If using s.17 reliance (obtaining certified copies of ID & address verification), have you been able to confirm the authenticity/professional status of the certifier?
· Has our client been cooperative in the process or have they delayed providing ID and address verification / appeared reluctant to do so?
FINANCIAL PROFILE OF CLIENT
· Does the stated source of wealth / source of funds and the amount of money involved stack up with what you know of our client, for example given their age and occupation? (evidence of SoW required in high risk clients/transactions)
· Is our client involved in / run a high risk or high cash turnover business?
· Could the type of transaction be used for the purposes of money laundering or is it at a higher risk of money laundering?
– Eg, Will / Power of Attorney – lower risk
– Estate Agency / Conveyancing / Commercial Property – higher risk
· Does the transaction make sense or is it overly complex given the underlying nature of the business being conducted?
· Does it make sense that our client has asked Purple Frog to carry out this type of transaction? (e.g. is it within our area of expertise/local geographical area?)
VALUE OF TRANSACTION
· Does the value of the transaction appear to fall within the financial means of our client, given their income and savings?
· Any overpayments of rent which are more than 3 months should be flagged to the MLRO.
· Any overpayments of fees from clients which are more than 25% higher than due should be flagged to the MLRO.
SOURCE OF FUNDS
· Is the source of funds clear and identifiable?
· Are funds coming from a recognised financial/credit institution or are they personal funds?
· Is any funding coming from overseas? Where from? Who from? Connection to client?
· Are any of the funds being paid by a third party otherwise unconnected to the transaction?
· Does our client seek to change the source of funds at the last minute?
· Has our client paid excess funds into our client account? Why/How?
DESTINATION OF FUNDS
· Has our client requested that free proceeds be paid to someone other than a lender or themselves?
· Are free proceeds to be paid to an overseas account?
4. Customer Due Diligence
Point at which identity documents are required
When instructed to sell a property
When a sale is agreed
When instructed to advertise/manage a property
When the tenant signs the tenancy agreement
Details required from tenants are as per Right to Rent Legislation, see references below.
Documentation require from Vendors, Buyers and Landlords:
– A photograph on an official document which confirms their identity (passport/driving licence)
– Residential address or date of birth.
– This is usually covered by a passport or Driving Licence plus a current utility bill or bank statement.
– Confirmation of status as director or partner if part of a legal entity (partnership/trus/ltd etc)
5. Reporting Suspicious Activity
5.1 Money Laundering Reporting Officer (MLRO) / Nominated Officer
The Nominated Officer for employees to report suspicious activity to is:
Name: Patrick Garratt
Position: Managing Director
Mobile: 07817 793 828
Email address: firstname.lastname@example.org
5.2 Government Guidance:
Anyone in our business must report any suspicious transaction or activity they become aware of to the nominated officer. It’s the nominated officer’s responsibility to decide whether they need to send a report or ‘disclosure’ about the incident to the NCA. They do this by making a SAR.
The nominated officer must normally suspend the transaction if they suspect money laundering or terrorist financing. If it’s not practical – or not safe – to suspend the transaction, they should make the report as soon as possible after the transaction is completed.
The NCA receives and analyses SARs and uses them to identify the proceeds of crime. It counters money laundering and terrorism by passing on important information to law enforcement agencies so they can take action.
Our nominated officer can send a SAR to the NCA. It’s easiest to send the report online.
The NCA website explains how to send a report.
If you need help with a report you can contact the NCA.
The NCA will usually reply to our report within 7 working days.
6. Record Keeping
6.1 What are records
“Records” can include transactions, receipts, cheques and customer correspondence – either original copies, photocopies, scanned or electronic copies.
6.2 Record Retention
Purple Frog keep a record of all customer checks we carry out, including the relevant paperwork. Records must be kept for five years from the point that a business relationship ends or from the date a transaction is completed.
Annual audits of all branches will be carried out and recorded.
7, Staff awareness and training
7.1 Initial training
It is the responsibility of the Nominated Officer to ensure all staff members have completed essential training on our Anti-Money Laundering responsibilities and record such training.
7.2 On-going training
It is the responsibility of the Nominated Officer to share any updates regarding Ant-Money Laundering with senior managers to share with their teams.
Right to Rent: https://www.gov.uk/check-tenant-right-to-rent-documents
Who needs to register HMRC: https://www.gov.uk/anti-money-laundering-registration
Last updated: September 2023
Updated by: Patrick Garratt