Money Laundering Policy

The law requires that the Agent obtain and verify satisfactory evidence of identity from Clients and any end-user of the Services where the Client is an intermediary.

The Agent is entitled to delay implementing any instructions until the provision of satisfactorily verified evidence of identity in the form required by it and the Agent shall have no liability to the Client or to any other person where any loss, damage or delay is caused by the Agent’s need to comply with any statutory or regulatory requirements.

We have reviewed the Money Laundering Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

Appointment of Nominated Officer

Our nominated Anti Money Laundering Officer at NG Chartered Surveyors is Charlotte Steggles, who we report any suspicious activity to. This would in turn be reported to the NCA.

Reporting Process

We have prepared a NG Anti Money Laundering Reporting Process document and completed a written risk assessment which identifies how and where the business is vulnerable to money laundering, terrorist financing and proliferation financing.

We apply a risk based approach to mitigating and managing the residual risks which focus more effort on the higher risks.

Client Information Stored

We have created an online password protected client folder where all documentation relating to financial checks, are stored.

Personnel, Policies & Procedures

We have also prepared a written policy statement, controls and procedures which show how NG Chartered Surveyors manage the risks of money laundering, terrorist financing and proliferation financing in the risk assessments.

We will review this statement on a regular basis to ensure any changes to the business, and exposure, are captured.

We commit to those completing this activity are appropriately trained and equipped to implement policies in support of the tasks in hand.

These policies, controls and procedures are communicated to all personnel who have a client facing role within the business.

We commit to monitoring the effectiveness of the business policy, controls and procedures and will make improvements where necessary.

We have also implemented a procedure whereby two client files are chosen at random every 3 months as a spot check from the Agency and Management teams to ensure compliance – Anti Money Laundering File Review Checklist is then completed.

Suspicions Raised

Should any suspicious reporting be flagged via the Smart Search forum, we would implement our Suspicious Reporting Procedure which would determine whether it is necessary for an Internal Suspicious Report Form be completed, and an assessment of the party in question is determined internally. Or whether it is necessary for an Anti-Money Laundering Risk Assessment Form to be completed. In this instance we would also report this using the SAR portal reference and logged via Gov.uk.

Policies Reviewed

All policies and procedures including personnel training were reviewed 11 April 2025, next scheduled to be completed by 15 January 2026.