Anti-Money Laundering (AML) Policy

Days Lettings and Estates Limited
Portsmouth, Hampshire
Effective Date: February 2025
Last Revied Date: February 2026

Policy Statement

Days Lettings and Estates Limited are committed to preventing money laundering, terrorist financing, and financial crime. As a residential estate and letting agent operating in Portsmouth and Southsea area, with a single office handling residential sales and letting we comply fully with:

• Proceeds of Crime Act 2002 (POCA)
• Terrorism Act 2000
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (as amended)
• Sanctions and Anti-Money Laundering Act 2018
• UK GDPR and Data Protection Act 2018

We adopt a risk-based approach proportionate to our size, structure, and transaction profile.

This policy applies to all employees, contractors and agents acting on behalf of Days Estates and Days Lettings Limited particularly in transactions involving:

• Property Sales (Estate Agency activities)
• Residential lettings where the monthly rent is equal to or more than 10,000 euros
• Any other activities that fall under the Money Laundering Regulations

Business Profile & Risk Assessment

Business Overview

• One office located in Southsea
• Residential sales
• Residential letting and management
• Management of purpose-built student accommodation
• No overseas branches
• No high-value commercial transactions

Geographic Risk

Primary market: Southsea and Portsmouth areas.

Higher risk indicators would be:

• Transactions involving customers living or resident overseas
• Customers based in the UK but living outside of our primary market areas

Client Risk

We assess client risk based on the type of client, their background and behaviours, including but not limited to:

• Politically Exposed Persons (PEPs)
• Non-UK residents
• Corporate structures
• Cash purchasers
• Unusual or complex funding arrangements
• Customers unwilling to provide identification or source of funds information

Product/Transaction Risk

Higher risk indicators include:

• All-cash purchases
• Third-party funding
• Rapid re-sales of property
• Significant price under/over valuation
• Unexplained source of funds
• High value lettings
• Transactions involving ‘shell’ companies disguising beneficial ownership

Delivery Channel Risks

Higher risk indicators would be:

• Remote online interactions as opposed to face-to-face meetings with customers
• Transactions involving third party agents or introducers who might not have undertaken customer due diligence

Compliance Structure

Days Estates is registered with HMRC for money laundering supervision which is renewed each year

Nominated Officer (Money Laundering Reporting Officer – MLRO)

The MLRO is responsible for:

• Receiving internal suspicious activity reports (SARs)
• Submitting SARs to the National Crime Agency (NCA)
• Maintaining AML records
• Staff training and policy updates
• Ensuring compliance with HMRC supervision
• Ensure records are kept for at least 5 years

Appointed MLRO: Jodie Day

Customer Due Diligence (CDD)

CDD is completed and is mandatory for all sellers, buyers, landlords and tenants. Days Estates has appointed Credas to undertake all CDD, AML and sanctions checks

• Before establishing a business relationship
• Before marketing a property
• Buyers before agreeing a sale
• For landlords before letting
• Tenants before agreeing a let
• When suspicion arises
• When information changes

Sellers & Landlords

Through our appointed provider we obtain:

• Full name
• Date of birth
• Residential address
• Proof of ID (passport or driving licence)
• Proof of address (utility bill/bank statement dated within 3 months)
• Evidence of property ownership

Buyers and Tenants

Before issuing a Memorandum of Sale, we obtain through our appointed provider:

• Proof of ID
• Proof of address
• Source of funds evidence (where applicable)
• Source of wealth (where applicable)
• Mortgage agreement in principle (if applicable)

4.3 Corporate Clients

Through our appointed provider we obtain:

• Certificate of incorporation
• Registered office address
• Director identification
• Beneficial ownership details (25%+ ownership)
• Companies House verification

Source of Funds & Source of Wealth

For purchases we require evidence proportionate to risk of the source of funds or source of wealth.

Acceptable documents include:

• Bank statements
• Completion statements from previous sale (verified by your solicitor)
• Savings account statements
• Gifted deposit declaration (with donor ID verification, verified by your solicitor)
• Probate documentation (if inheritance, verified by your solicitor)

Enhanced Due Diligence (EDD)

EDD is applied where:

• Client is a Politically Exposed Person (PEP)
• Client resides in high-risk country
• Transaction appears unusually complex
• Suspicion arises

EDD measures include:

• Additional ID documentation
• Independent source of funds verification
• Approval of the Money Laundering Reporting Officer (MLRO)
• Ongoing monitoring of the transaction for changes to funding, people and address details

Ongoing Monitoring

We monitor:

• Changes in transaction structure
• Changes in funding
• Unusual urgency
• Inconsistencies in client information
• Changes to people involved in the transaction

CDD is refreshed where considered necessary after discussion with the MLRO.

Suspicious Activity Reporting (SAR)

Internal Reporting

All staff must report suspicions or reasonable grounds for suspicion immediately to the MLRO using an internal Suspicion Activity Report  (iSAR)

External Reporting

The MLRO will:

• Evaluate suspicion
• Submit SAR to the National Crime Agency (NCA) where required
• Request Defence Against Money Laundering (DAML) where permission to proceed with a transaction involving suspected criminal property

Tipping off

Once suspicions have been raised with the MLRO the member of staff raising the suspicions must not, under any circumstances, discuss those suspicions with the individual or individuals concerned or with any other members of staff within the company.

The penalties for ‘tipping off’ are up to two years in prison and an unlimited fine.

Record Keeping

We retain records for 5 years from the end of the business relationship:

• Client identification documents
• Risk assessments
• SARs
• Transaction records
• Training records

Records are stored securely in compliance with UK GDPR.

Staff Training

All staff receive AML training upon joining the company, during their induction period and annually thereafter.

• AML induction training
• Annual refresher training
• Updates when legislation changes

Training includes:

• Identifying red flags
• Reporting procedures
• Data protection obligations

Training delivery can be:

• In person
• Online

Training attendance is recorded on staff personnel files

Red Flag Indicators

The following are examples of situations that might give rise to suspicion which would initiate the submission of a suspicious activity report, these include:

• Customers reluctance to provide ID
• Third parties paying deposits
• Purchase significantly above asking price
• Properties with frequent unexplained ownership changes
• Multiple quick re-sales
• Complex ownership structures
• Transactions involving shell companies
• Clients paying high rents to themselves via shell companies

Sanctions Compliance

We screen all clients against UK sanctions lists.

If a match is identified:

• Freeze activity
• Notify the MLRO
• Report to the Office of Financial Sanctions Implementation (OFSI)

Data Protection

All AML data collected by us or by our appointed provider is:

• Collected lawfully
• Stored securely
• Used only for compliance purposes
• Deleted after statutory retention period (5 years)

Our Privacy Policy Statement can be found on our website

Internal Controls

We maintain and update:

• Written AML policy
• Firm-wide risk assessment
• Internal reporting procedures
• Annual compliance review of risk, policies and procedures
• Risk assessment and procedures based upon industry guidance