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Anti Money Laundering (AML) Policy

 

Anti Money Laundering Policy
MAS Lettings and Management Limited
Effective Date: 30th November 2022
Reviewed:13th October 2025
 

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1. Policy Statement

MAS Lettings & Management Limited is committed to preventing money laundering and terrorist financing activities in accordance with UK law. We will take all reasonable steps to detect and deter the use of our services for money laundering purposes, and we will comply fully with all applicable legal and regulatory obligations

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2. Scope

This policy applies to all employees, directors, contractors, and third parties engaged in property management activities on behalf of MAS Lettings & Management Limited including (but not limited to):

• Lettings and lease management

• Rent collection

• Property maintenance coordination

• Client fund management

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3. Legal and Regulatory Framework

This policy complies with the following UK legislation and guidance:

• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)

• The Proceeds of Crime Act 2002

• The Terrorism Act 2000

• HMRC Guidance for Money Laundering Supervision

• The National Crime Agency (NCA) Reporting Requirements

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4. Money Laundering Reporting Officer (MLRO)

The company has appointed a Money Laundering Reporting Officer (MLRO) responsible for overseeing AML compliance.

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The company has appointed a Money Laundering Reporting Officer (MLRO) who is responsible for overseeing AML compliance.

MLRO Name: Michelle Sawdyk

Contact Email: rent@maslettings.co.uk

Phone: 07377 439 203

 

The MLRO is responsible for:

• Receiving and evaluating internal suspicious activity reports (SARs) • Deciding whether to report to the NCA

• Maintaining AML records

• Ensuring ongoing compliance and training

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5. Customer Due Diligence (CDD)

We will carry out appropriate Customer Due Diligence (CDD) checks before establishing a business relationship or carrying out a transaction.

This includes: • Identifying and verifying the identity of the customer and any beneficial owners

• Assessing the purpose and intended nature of the business relationship

• Obtaining proof of address and photographic ID CDD is required

when:

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• Establishing a new client relationship

• Managing client funds

• There is suspicion of money laundering

• Customer information changes

• There are doubts about previously obtained identification

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6. Enhanced Due Diligence (EDD)

EDD must be applied in higher-risk situations, including:

  • Clients based in high-risk third countries;

  • Politically Exposed Persons (PEPs) and their associates;

  • Unusually large or complex transactions;

  • Non-face-to-face client onboarding.

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EDD may involve obtaining additional documentation, verifying information from independent sources, and obtaining senior management approval before proceeding.

 

Enhanced Due Diligence (EDD) EDD is required in higher-risk situations, including (but not limited to):

• Politically Exposed Persons (PEPs)

• Clients based in high-risk third countries

• Unusually large or complex transactions

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7. Ongoing Monitoring​

​We will retain all AML-related documents for a minimum of five (5) years from the end of the business relationship or the completion of the transaction. Records include:

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• Identity and verification documents

• Risk assessments

• Client correspondence

• Transaction records

• SARs and internal reports

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8. Record Keeping

Records of all CDD, EDD, and AML-related activities will be retained for a minimum of 5 years from the end of the business relationship.
Records include:

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  • Customer identification and verification documents;

  • Risk assessments and due diligence forms;

  • Correspondence and transaction history;

  • Internal and external SARs.

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All records will be stored securely in compliance with the UK GDPR and Data Protection Act 2018.

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9. Suspicious Activity Reporting (SAR)

All staff must report suspicious activity to the MLRO immediately using the company’s internal reporting form. The MLRO will assess and, if necessary, report the activity to the National Crime Agency (NCA) via a Suspicious Activity Report (SAR).

Suspicious activity may include:

• Reluctance to provide ID or documentation

• Complex or unusually large transactions

• Third-party payments or unconnected individuals involved

• Overpayments and requests for refunds

• Unexplained wealth or cash-based transactions

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10. Training

All relevant staff must complete AML training at least annually. Training includes:

• Overview of AML laws and responsibilities

• How to conduct CDD and EDD

• Recognising suspicious activity

• Reporting procedures New staff must receive AML training as part of their induction process.

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11. Risk Assessment

MAS Lettings & Management Limited conducts regular AML risk assessments covering:

• Types of clients

• Geographic risks • Nature of transactions

• Delivery channels The risk assessment is reviewed annually or when significant changes occur.

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12. Responsibilities

All employees are responsible for:

• Complying with this policy

• Remaining vigilant to signs of money laundering

• Reporting suspicions to the MLRO Management is responsible for ensuring that sufficient resources, training, and controls are in place to meet AML obligations.

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13. Breaches of Policy

Failure to comply with this AML policy or relevant legislation may result in:

• Internal disciplinary action

• Termination of contract or employment

• Regulatory fines and/or criminal prosecution

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14. Review and Approval

This policy will be reviewed annually by senior management and updated as necessary to reflect changes in law or company operations.

Approved by: Michelle Sawdyk

Managing Director

13th October 2025

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