Anti-Money Laundering (AML) Policy

Cints Estate is required to comply with UK anti-money laundering regulations. This policy explains the checks we undertake and what we require from clients in order to prevent financial crime and ensure regulatory compliance.

Cints Estate is committed to maintaining robust controls aimed at countering money laundering and the financing of terrorism. Our policies align with the requirements set out in the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (Statutory Instrument No. 692).

Cints Estate is registered with HMRC for the purposes of anti-money laundering supervision and operates in accordance with the provisions of the Money Laundering Regulations 2017. Our compliance framework is based on a risk-based approach designed to identify, assess and mitigate potential financial crime risks within our business operations.

1.1 Purpose

We conduct anti-money laundering checks to prevent financial crime and to comply with applicable UK legislation, including the Money Laundering Regulations 2017.

Our procedures are designed to identify and prevent the use of our services for money laundering, terrorist financing or other illicit financial activity. While we recognise that the majority of our clients act legitimately, we maintain safeguards to identify transactions or relationships that may present a higher level of risk.

1.2 Identity Verification

Prior to providing services, we are required to verify the identity of our clients.

Identity verification may include:

Government-issued photo identification (such as a passport, driving licence or national identity card)

Proof of residential address (such as a utility bill or bank statement dated within the last three months)

Where document-based verification is used, the identification must clearly show the individual’s full name and either their date of birth or residential address.

For clients where face-to-face verification is not possible, enhanced due diligence measures may be applied. These may include certified documentation or additional identity verification checks through approved electronic verification providers.

For corporate clients, partnerships or other legal entities, we will collect relevant information including:

Company registration number

Registered business address

Details of directors and authorised representatives

Identification of shareholders or beneficial owners holding 25% or more of the entity

Identity checks are mandatory before marketing property, negotiating transactions, or entering into property agreements.

1.3 Source of Funds

Where applicable, we may request documentation to confirm the source of funds used in property transactions or investments.

This may include evidence such as:

Bank statements

Investment records

Loan agreements

Other financial documentation demonstrating legitimate origin of funds

These checks form part of our risk-based approach to ensuring that transactions conducted through our services are legitimate and compliant with regulatory requirements.

1.4 Record Keeping

Cints Estate maintains strict record-keeping procedures in accordance with statutory requirements.

We retain relevant documentation relating to:

Client identity verification

Transaction records

Source of funds information

Due diligence assessments

Records are retained for a minimum period required under applicable legislation and may be made available to regulatory authorities where required.

1.5 Reporting and Monitoring

Cints Estate operates an internal reporting framework designed to identify and escalate suspicious activity.

Staff members are trained to recognise indicators of potential money laundering or terrorist financing. Any concerns are reported internally to the designated Money Laundering Reporting Officer (MLRO).

Where appropriate, the MLRO may submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA) in accordance with legal obligations.

Indicators of suspicious activity may include:

Reluctance to provide identification information

Use of intermediaries to obscure the identity of parties involved

Transactions lacking a clear legitimate purpose

Third-party payments with no clear relationship to the transaction

1.6 Staff Training and Compliance

Cints Estate places strong emphasis on ongoing staff training to ensure a clear understanding of anti-money laundering legislation and compliance responsibilities.

All employees receive AML awareness training as part of their induction and are regularly updated on regulatory requirements and risk indicators.

1.7 Data Security

All AML compliance data is processed and stored securely in accordance with applicable data protection laws.

Personal information collected as part of identity verification and compliance procedures is handled confidentially and used solely for regulatory and compliance purposes.

1.8 Commitment to Compliance

Cints Estate remains committed to maintaining the highest standards of anti-money laundering compliance, promoting transparency in our operations and safeguarding the integrity of our business.